Friday, 25 April 2014

My submission in response to Traffic Regulation Order Consultation for the Cheltenham Transport Plan/Boots Corner partial closure

I have had to remove the graphs in my letter as they are from PDFs and I am not sure how to add a PDF to this blog - the graphs are viewable on the website given below though.......


Your ref HBL/52468


Dear Sir,

I am writing as Councillor for College Ward on Cheltenham Borough Council and County Councillor for Charlton Park and College Division to formally object to the Traffic Regulation Orders currently being consulted on which relate to the Cheltenham Transport Plan.

Please can I request that this submission and supporting documents from my survey which are attached are reproduced in full for all members of the County Council’s Traffic Regulation Committee? I would like to ask them to spare a few minutes to read through this carefully and to recommend that the TROs being consulted on are refused.
 
The ‘prize’ of reducing traffic at Boots Corner is not what people who support pedestrianisation want, it will not be safe and it will not deliver significant improvements to the public realm because of the need to facilitate large buses going through the space

At the heart of these plans are proposals which will see a reduction in traffic at Boots Corner, although not full pedestrianisation. I believe that most people who have expressed support for the Boots Corner part of the plans during last year’s questionable public consultation actually supported full pedestrianisation and not the fudge of partial closure.

This opinion is based on the result of a survey I have carried out on the Boots Corner aspects of the plans. This online survey was promoted through email contacts, twitter and via a paid for Facebook promotion aimed at men and women living in Cheltenham over the age of 18. 

The online survey received 313 completed responses out of 316 responses. The graph results of the survey and associated comments from respondents will be attached to the email I am sending this representation with - but some are included in the body of this submission too.


I added the open question for people to comment after the survey had started, all of the comments received are included and show a range of opinions. The survey was set so that only one response could be sent per PC so as not to distort the results; also I could see the IP addresses of the respondents to ensure that responses were individual.

Interestingly, although the number of people filling in the survey varied by week, the data trends for the response to the questions remained fairly constant. This data trend is important as over the different weeks I advertised the survey differently. In the earlier weeks I mainly made people I know aware of it but in later weeks it was promoted to an unknown but local population through Facebook and Twitter.  

Details of the data trend are available to view on the web at Boots Corner online survey results The percentages shown in the charts are automatically calculated by Survey Monkey who hosted the survey.

Despite these differences in response rates and audience the results are strikingly consistent; however they are also very different to the results received during last year’s informal consultation. At the very least I believe the results of my survey must undermine the results of last year’s survey which asked only a very small number of leading questions, mainly focussing on the design of public realm at Boots Corner and people’s personal details rather than asking for detailed views on the impact of the traffic changes.

The results of last year’s consultation have been used to justify taking the plans to this stage of Traffic Regulation Orders but I believe very strongly that this should not have happened. The consultation asked leading questions; many people affected by the proposals did not take part in the consultation as they were not happy with the wording and a petition that was specifically worded to ask signatures to be counted as opposing the plans was not included when assessing the level of support or opposition to the plans.
 
The first question in my survey asked: Do you agree with Cheltenham Borough Council's plans to partially close Clarence Street at Boots Corner to some through traffic?

The results of my survey showed only 17.57% (55) respondents agreed. However, of those 55 people, 21 answered that they supported full pedestrianisation on at least one of the following 3 questions which asked for a more detailed view on the plans. 5 of the 55 respondents who said they agreed with partial closure of Boots Corner answered at least one of the following 3 questions by saying they needed more information. One person ticked that they disagreed and all vehicles should still carry on going through Boots Corner on one of the following 3 questions.

Hence of the 55 respondents who said they supported the plans only 28 answered the questions that followed in a way that was wholly consistent with that opinion. Out of a response rate of 313 that is nowhere near the level of endorsement that the consultation held last year allegedly achieved. By my calculations, this response to my questionnaire showed only an 8.95% support for partial pedestrianisation.

The results of my survey showed that 24.6%* (77) said they disagreed with the proposals because they favoured full pedestrianisation. If the 21 people who said they supported the scheme but actually went on to answer that they supported full pedestrianisation were added to that response it takes support for full pedestrianisation to approximately 31.01% (98). It is my belief that support for full pedestrianisation has been taken to date to be implied support for partial pedestrianisation - but I believe there are very important reasons why doing this is utterly flawed. Those who wish the road layout to remain the same was 45.69%.


It is very important that decision makers understand what is behind the views expressed in my survey which I believe were replicated in the consultation last year but not presented properly, hence distorting what respondents were telling the councils. The issue of the improvement to the public realm, the safety of pedestrians especially those with disabilities as well as decent access to the town centre are THE key issues around the specific changes at Boots Corner, although concerns around the displaced traffic are also extremely important.
 
The sixth question in my survey asked: Do you believe that allowing buses and taxis to share space with pedestrians at Boots Corner will be safe for people with disabilities, including those who are blind or visually impaired?

The council’s consultation last summer did not dig too deeply on people’s views on pedestrian safety at Boots rather focusing on how the improvements could look – whilst at the same time putting the faint outlines of the large buses still going through the space. But this is such a fundamentally important issue. The County Council as highways authority must be responsible for creating spaces that are accessible and user friendly for all - not just those who are able bodied.

As you can see the response to this was a fairly resounding NO, people do not think what is planned will be safe. Over 67% said they did not believe allowing buses and taxis to share space with pedestrians at Boots Corner will be safe for people with disabilities.

Fears about the safety of shared spaces are well documented. A pensioner was killed by a bus in a shared space in Coventry. RNIB and Guide dogs for the blind have campaigned against shared spaces. At Boots Corner the crossing which many (no doubt able bodied people) claim is a barrier for pedestrians is actually an enabler for disabled people.


With no vehicles going through this space it would be easy to see that it could be safe for people of all ages and abilities but to remove the crossing and yet allow through a significant number of large buses, taxis and cycles will create a significant barrier for people with sight problems and for others too.

There are very real concerns about the safety of creating a shared space at Boots Corner, for example because of the size of the space at Boots Corner, the behaviour of existing bus drivers and the needs of those with sight problems. I have witnessed very recently (in April 2014) a Stagecoach bus driving only a foot away behind a male pedestrian and his young son outside the section of the High Street which is partially pedestrianised outside Primark. The bus was travelling at low speed but moving and so close to the pedestrians that if they had stopped suddenly they would have been hit.

If you were partially sighted and there was no crossing, crowds of people and buses and taxis going past would you feel safe crossing here?

Indeed the response from Stagecoach to last year’s consultation said that they were worried that the Council was not focussing enough on the practical side of how the space will work. My viewpoint is not anti-bus at all; I am equally concerned about the stress for bus drivers having to negotiate through Clarence Street if this proposal goes ahead. Boots Corner becomes extraordinarily busy with pedestrians at times; it will be a real headache to drive a bus through there negotiating the huge crowds in a small space.

Because of the concern that people have about the safe use of the space at Boots Corner, responses from people during last year’s consultation indicating support for full pedestrianisation must not be taken as implicit support for reducing the amount of traffic and taking the crossing away. This is clear from my full survey results. Most people say they do not believe a shared space will be safe and most people favour either full pedestrianisation or to keep the road as it is.

I just want to touch very briefly on the supposed improvements in public realm that the scheme is promising to deliver. Buses, Hackney carriage taxis and cycles will still be allowed through Boots Corner but cars, private hire taxis, vans, HGVs etc will all have to use longer routes through residential roads in the town.

The space will not be that relaxing or pleasant to be in, it is the large buses which already make the place really unpleasant and noisy but they will continue through. Clearly there is convenience and access issues which mean that allowing buses through is vital however it does reduce significantly the public realm gains that could be delivered. These benefits and improvements have been exaggerated both during consultations and in presentations to Cheltenham councillors.

With significant traffic moving through the area including buses waiting with their engines running, it is almost mis-selling to suggest people will want to idle away their time there more than they currently do. One only has to look at the pedestrianised section outside Marks and Spencers or outside Cavendish House to see that paving is ruined even by a small amount of delivery vehicles accessing the shops there. With large buses running through Clarence Street, paving it will be out of the questions and it is very difficult to see how the space will look more attractive if coloured tarmac is used to spruce the place up.
 


I can see it becoming an eyesore after a short time due to the traffic that will still be going through and the impact on the wear and tear of the road surface. Improvements could and should be made to the area without the need to change traffic flow. This has happened recently in the part of the Promenade outside the Municipal offices (a road which in my view would be a very much better public realm space than Boots Corner if fully pedestrianised, creating a beautiful civic square centred around the war memorial. Instead it is the most attractive bus station and taxi rank in the country, such a waste).



If Clarence Street and other nearby roads are properly resurfaced, along with new paving on the pedestrian parts it would lift the area. This is already a busy area and a popular place for people to meet up due to its location. The footfall in the Lower High Street is high and the Brewery Phase 2 development is going ahead even though it is not certain that the Boots Corner partial closure will happen. If there were the sorts of problems that some of the propaganda about this scheme suggests people would avoid it and the Lower High Street would be deserted. Neither is the case.
 
Boots Corner must be safe for all and access for those with disabilities is also essential

A key tension in the plans as they stand is resolving the issue of the safety of the proposed shared space at Boots Corner for people with sight problems with the issue of easy access to the shops and suitable parking for those who are disabled/have mobility problems.

I specifically asked a question in my survey about allowing taxis to access Pittville Street to the side of Marks and Spencers because I know from anecdotal evidence that many elderly shop at M&S and rely either on taxis (including private hire) to drop them off or on relatives who use their blue badge to park nearby. 

The side access at M&S is vital in enabling people who wish to shop there but cannot walk long distances to continue to do so. I would actually go further and say access for blue badge holders to park on Pittville Street or private hire taxis that can be booked to take people with sight or mobility problems is really essential to provide fair and easy access although retaining a rank for Hackney carriage taxis would be the bare minimum.

Whilst not perfect, the current road layout allows good access for people with mobility problems to the town centre. Also the clearly defined pedestrian only areas and controlled crossing create a predictable and enabling environment for people who have sight problems. Please when you are making your decisions on these TROs imagine you either cannot see properly or have other access needs and imagine how the proposed changes would affect you being able to have the freedom to use the town centre compared to what currently exists.

The 'improvements' at Boots Corner which will only see a reduction in traffic not a removal of traffic will not be significant enough to warrant the disruption caused by the partial closure of Boots Corner in terms of displaced traffic around the town

Whilst there are some parts of the Cheltenham Transport Plane which would be sensible without the partial closure of Boots Corner, the impact of traffic displaced from Boots Corner on other already congested residential roads will be unacceptable.

The closure of Boots Corner itself will create a substantial amount of displaced South to North traffic. Routes most likely to be affected include already congested roads such as Bath Road, St Luke’s Road, College Road (very significantly in either direction), Hewlett Road, All Saints Road, Fairview Road, Gloucester Road, Old Bath Road, London Road, Honeybourne Way, St Georges Street, Ambrose Street, St James Square, St Georges Place and Montpellier Terrace.


The impact on College Road is particularly worrying, as it is already very congested. Not only are there residents living there whose lives will be affected but there are a number of other sensitive land uses which will be harmed by an increase in congestion.



The access to the towns A&E department is on College Road, as is Sandford Park which is cut in two through College Road. Cheltenham College boarding houses are on this road as is St Luke’s Church. It is very important not only for people living there but the wider Cheltenham community that congestion does not get worse here as a result of the transport plan. However, I believe very strongly that congestion in both directions will get considerably worse as a result of the planned changes.

Increasing congestion and making journey times more unpredictable will harm many local businesses. Not all businesses in Cheltenham are based in the town centre retail area, small traders and those who need to get about the town during the working day in a work vehicle will be affected by the increased congestion.

Displaced traffic will move pollution from a transient town centre population of shoppers and those passing through, towards residential roads with static populations of residents. This will have serious health implications for many town centre residents and it would be negligent for any public body to deliberately make changes in this way that would harm the health of its citizens.
 
The eighth question in my survey asked: Gloucestershire County Council's traffic modelling shows that a number of routes will experience more congestion as a result of the Boots Corner Partial closure. Are you concerned about the impact that traffic displaced from Boots Corner would have on pollution and congestion elsewhere in the town? 

The impact on congestion from displaced traffic is of concern to people with almost 79% of people expressing some level of concern about this with the largest number of respondents saying they are very concerned.


Much has been said by campaigners about the quality of the traffic modelling, that it might be state of the art but it does not include state of the art inputs. Factors like the thousands of houses allocated by the Joint Core Strategy in the North West and South West of Cheltenham were not included. Nor was the very large increase of traffic during race week or when one of the many festivals is happening in the town or the impact of the development of a new Morrison’s supermarket on St Margaret’s Road.

It is impossible to predict accurately how congestion will be affected, say the officers overseeing the plans, this has made getting mitigation works for roads likely to be affected very difficult. Those who want the Boots Corner changes seem to ignore or gloss over this impact whilst those who are terrified of the impact of the changes on the roads where they live are left thinking that the council simply does not care about their quality of life or health.
 
It’s not just about Boots Corner......

As well as the impact of changes at Boots Corner I have concerns about other aspects of the Plan and associated TROs which I really hope will not get forgotten because of the contention of the Boots Corner changes. The changes at Oriel Road and Imperial Square (in front of the Town Hall) could have significant traffic congestion implications. Both roads will go down from two lanes to one lane east to west to allow for two way traffic.

The Promenade, already very congested at peak times, will have a new right hand lane turn into Imperial Square which could cause long delays to traffic flowing down the Promenade. As well as sending displaced traffic through St Luke’s and College Road via Bath Road, there is a risk of considerably more vehicles travelling through Montpellier Terrace.

I am particularly opposed to the proposal to reduce Bath Road between High Street/Vernon Place and the junction with the Playhouse to one lane (although the TRO consultation is a bit too vague on the details of this and so many people will not realise that is what is planned).

This will cause long tail backs along the High Street and potentially make College Road a rat run (north to south) as more vehicles use that route to avoid the congestion on Bath Road. This could also impact on Bath Parade. It is important to note that these two roads have experienced severe flooding from the River Chelt in the past on a number of occasions.

Also at the junction with the Playhouse, traffic moving south along Bath Road will be able to go straight on or turn right into Oriel Road. This happens now of course, but with Bath Road down to one lane and Oriel Road proposed to become two-way there will be cars turning out of Oriel Road making a right turn which could cause much more congestion along Bath Road.

I would urge you to note carefully the impact of these changes, the impact on pedestrians trying to cross anywhere near this area and the impact on congestion associated with the proposed changes.  There is a zebra crossing proposed to be installed near the Playhouse, which I imagine many will welcome.

However I do have worries that this will not be observed by all motorists. I get regular complaints about a zebra crossing on Thirlestaine Road which people say is not observed and people feel unsafe using it. With longer journey times along Bath Road due to the reduction in lanes motorists could feel impatient and ignore the zebra crossing.

This is true of the other plans to replace controlled crossings with zebra crossings. I can't help feeling whoever designed this scheme is relying on the zebra crossings being introduced to try and mitigate the impact on congestion of the other changes. These crossing changes, particularly on Royal Well Road are going to make things very much more difficult for pedestrians to cross. The road network is going to become so gridlocked, particularly during race week or during one of the many festivals, vehicle drivers will be tempted to carry on over the zebra crossings when people are waiting to try and make up their journey time.

Other issues of concern are the changes to the controlled lights at the junction of Bath Street and Vernon Place with Bath Road. With Bath Road being taken down to one lane and the crossing changed to a puffin crossing there will be times where exiting from Bath Street (and Cambray Place) or Vernon Place on to Bath Road could take a very long time, this is a real worry for people living there.

As you will see from the detail in this submission I have so many concerns about the scheme it is impossible to suggest amendments to mitigate the impact. Ideally I would like you to reject these plans as they stand. Cheltenham’s road network does need attention but this is not the right solution and it simply does not have the backing of the town’s residents.

Having said that, it is essential that if you do decide to proceed with the scheme that the Boots Corner element MUST be trialled. There must not be a situation where irreversible changes are made. If this goes ahead and creates safety or access problems for the disabled and for residents on roads with increased congestion the County must be able to put it right.

The wellbeing of our town hinges on getting any changes to our road network right. In my view the sensible thing would be, if this daft plan must be implemented, to make the junction changes except Boots Corner first. Once these have bedded in, then trial the changes at Boots for six months. In other towns and cities where shared spaces are planned they seem to trial them, why do the County seem to be so stubborn on this issue?

Yours sincerely,

Klara Sudbury,
Gloucestershire County Councillor, Charlton Park and College Division

Cheltenham Borough Councillor, College Ward