29 March 2018

A417 'Missing Link' - What's our view?

A417 Missing Link

The Cotswold Green Party strongly disagrees with both Option 30 and Option 12 on the grounds of:

  • Air quality impacts, climate change impacts and damage to the natural environment. Both Options have been assessed to increase greenhouse gas emissions due to increases in both traffic levels and speeds. This is inconsistent with the Government’s commitments under both the Paris Accord and the Climate Change Act.
  • Poor value for money and lack of evaluation against alternatives especially if environmental damage and degradation are taken into account
  • Knock on effects undermining overall objectives. No assessment has been made of the effects of increases in traffic on the A419/417 on the junctions  following in the road system, viz. the Seven Springs junction on the way into Cheltenham and the Hucclecote / Gloucester Business Park roundabout. 

We acknowledge that there is a problem with this stretch of road, but advocate:

  • The use of lower speed limits
  • Variable speed limits to help manage the flow of traffic at peak times
  • Proper enforcement of the speed limits through average speed cameras
  • Removal of the London sign on the M5 11a junction

Our full submission is below:


The proposed option
8 To what extent do you agree with our proposed Option 30?
Strongly disagree
Please provide any comments to support your answer::
Highways England have developed 30 potential routes for road expansion along the A417 responding to concerns about traffic delays and accidents, with the goal of removing the Air Balloon Roundabout, and creating dual carriageway where there is currently only single carriageway. A number of tunnel routes that would minimise damage to the Area of Outstanding Natural Beauty (AONB) and Site of Special Scientific Interest (SSSI) and have been discounted due to cost.
Highways England are seeking support for 'Option 30', a £485m project with an estimated 4% return on investment before negative environmental impacts are taken into account. That return is primarily predicated on journey time reductions during morning and evening averaging 4-5 minutes, and is considered 'low' value for money by Highways England's own calculations.
1) Both proposals represent extremely bad value for money, even in financial terms. If environmental damage and degradation is taken into account, these proposals will both have a negative value to society.
2) In putting forward these proposals, no assessment has been made of opportunities to avoid their construction by the reduction of traffic through this road segment.
3) Both Options are inconsistent with the current UK Government's "25 Year Environment Plan" recently put forward by DEFRA which states in Chapter 1 "Using and managing land sustainably", that the Government will: Embed an 'environmental net gain' principle for development, including housing and infrastructure.
Table 15.1 of the Technical Appraisal Report indicates that both Options would have 'Large Adverse' effects on Landscape, Historical Environment, Biodiversity and Water Environment, indicating a severe 'net loss' to all aspects of the environment in the surrounding area and therefore by no means can be judged to achieve an 'environmental net gain'
4) Both Options have been assessed to increase greenhouse gas emissions due to increases in both traffic levels and speeds. This is inconsistent with the
Government's commitments under both the Paris Accord and the Climate Change Act. The Druridge Bay opencast coalmine project has recently been refused
planning permission in the main due to its climate change effects and this project should be rejected on the same basis.
5) No assessment has been made of the effects of increases in traffic on the A419/417 on the junctions following in the road system, viz. the Seven Springs junction on the way into Cheltenham and the Hucclecote / Gloucester Business Park roundabout. Implementation of either Option 12 or 30 will inevitably cause calls for further expenditure in the future because of congestion at these junctions.

Option 12
9 Do you have any comments to make in relation to Option 12? (We will take these in to consideration as we develop the scheme)
Q2:
see previous answers in relation to option 30
Other options
10 As part of identifying route options, we’ve assessed over 30 options, including 6 as part of our further appraisal work. Do you have any
comments on any of the other options included in the assessment?
Q3:
The flaws outlined above are common across the road expansion schemes proposed. However, we note that local wildlife groups have advocated for tunnel solutions, as the only way to retain the link for flora and fauna as well as the natural beauty of the Cotswold Edge. If, following consideration of all alternatives (including public transport and traffic regulation), a road solution is still assessed as important, we believe tunnel options should remain under consideration to minimise the impact on the AONB and SSSI.

11 Is there anything further you would like us to consider in relation to improving the A417 Missing Link?
Q4:
We acknowledge that there is a problem with this stretch of road, but advocate:
- The use of lower speed limits
- Variable speed limits to help manage the flow of traffic at peak times
- Proper enforcement of the speed limits through average speed cameras
- Removal of the London direction sign on the M5 11a junction to reduce pressure on the A417/419


While it is likely that either of these road schemes may reduce casualties on the section of road, it is worth considering that many of the ‘accidents’ are caused by dangerous driving and poorly maintained HGVs. Neither of these causes are likely to be substantially ameliorated by either of these schemes.


Neither of the schemes will remove the fact that this road passes over one of the more exposed areas of countryside and is still liable to be blocked or rendered dangerous by extreme weather events. It therefore seems imprudent to add to its traffic load, particularly given UK Climate Impact Project future climate projections for a 20 -30% increase in winter precipitation in this area due to climate change.


We strongly advocate for a focus on road safety, recognising that there have been a number of fatal accidents in the vicinity of the Air Balloon roundabout. We are frustrated that very few road safety measures have been implemented at this intersection, despite it being an accident hotspot. We would advocate the use of lower speed limits, variable speed limits to help manage the flow of traffic at peak times, and proper enforcement of the speed limits through average speed cameras.


Ultimately, the reduction of traffic must be a priority. This will help to reduce CO2 emissions, and harmful NOx and particulate matter (PM 2.5 and PM 10)

The consultation documents state the objects of the scheme are:
Transport and safety
Environment and heritage
Community and access
Economic growth
Yet these objectives cannot be met by road building. A £0.5bn investment into the area could do much more to achieve these objectives if put into a range of schemes, rather than a single road.


We believe consideration should be given to a range of transport and local economic planning alternatives that reduce congestion, improve road safety, and improve local quality of life - whilst protecting and securing an Area of Outstanding Natural Beauty and Site of Special Scientific Interest: maintaining the attractiveness of Gloucestershire as a place to live, work and visit.

13 Do you have any feedback on this consultation - events, information provided, advertising etc?
Q6:
We welcome the opportunity to input into this process. However we feel that there are limitations to the information provided on the Options. Most significant of these is the lack of indication of the land take surrounding the carriageways on the plans.


We are concerned that the Do Minimum scenario has not been outlined in the consultation clearly as a comparator, and that likely air quality and climate change impacts have not been clearly presented as part of the main documents circulated to the public. The possibility of cost overruns removing any of the calculated financial returns from the scheme has also been lost in the volume of information.