Investing in the A40 – full response
5 November 2015
OXFORD CIVIC SOCIETY Response to Oxfordshire County Council consultation
We have some serious criticisms to make regarding the circumstances within which this consultation is being conducted, as well as observations on the analysis of the problems which the proposed options for action might be intended to address, and on the various solutions suggested.
Strategic planning void
The consultation material provides no explanation of why it is necessary to come to a view at the present time about longer term options for the A40 corridor. It is entirely premature to present the public with specific transport options purported to cost £100m and more in the absence of a coherent Oxford-regional land use or development strategy for a similar, i.e. longer-term time frame. Public investments on this scale will depend for their justification on facilitating particular major developments and alleviating highway congestion through the promotion of more efficient and sustainable transport modes.
It has been reported that the Oxfordshire Strategic Economic Plan will be reviewed and updated between November 2015 and March 2016, and it is inevitable that this review will consider development options likely to have a bearing on priorities for transport improvements across the Central Oxfordshire region, including for the A40 corridor. The current consultation is therefore premature on this count, since it is impossible for anyone, least of all the general public to reach appropriate conclusions on strategic highway improvement options when such uncertainty prevails. This consultation fails to make any reference to the forthcoming SEP review.
It is also misleading to imply that there might be opportunities in the near future to bid for Government funding for further investment in the A40 (beyond existing commitments) without acknowledging the need to assess priorities and cost-effectiveness across a wider area, or even across alternative route options for commuting traffic. The potentially-greater claims for investment in the A34 corridor and in the Rapid Transit schemes already proposed by the County Council for Oxford City are obvious examples.
Within its own narrow remit the consultation is pre-occupied with offering potential ‘solutions’ – but without making any serious attempt to define the nature and scale of the long term problem. Without this it is difficult to see how the merits of the various options can be assessed. In particular the consultation material provides no basis for determining whether the benefits of the more expensive options are likely to justify their additional cost – indeed whether there is a case for any investment beyond the ‘do minimum’ set of improvements already committed to.
The consultation is also presented as if in a policy vacuum. It does not explain relevant policies and proposals that the County Council has recently approved in its Local Transport Plan 4 (LTP4). Nor does it provide any guidance on how the options put forward contribute to or conflict with these. It is entirely possible therefore that the consultation might evoke a public response entirely at odds with the stated policy objectives of the Council – a very unhelpful basis on which to proceed.
The significance of the existing congestion problem is not in dispute. This derives principally from the limited capacity of the Wolvercote roundabout which results in long queues of traffic on the eastbound A40 approach for much of the day. However this problem is being addressed by the current Wolvercote and Cutteslowe roundabouts improvement scheme which provides for approximately a 30% increase on present traffic flows in addition to the traffic projected to be generated by the forthcoming Northern Gateway development.
In practice, traffic growth through the Wolvercote Roundabout will be reduced as a result of the planned link road through the development and additionally by the A40-A34 ‘strategic link’ if and when this is built. Traffic growth on the Eynsham – Wolvercote section more generally will be offset by transfers of motorists to the planned Park and Ride car park at Eynsham coupled with the eastbound bus lane to Dukes Cut, part of the agreed Local Growth Fund scheme. This scheme also includes improvements for traffic flow at the Eynsham and Cassington junctions.
Given these significant improvement works in the short term what is the nature, scale and incidence of the traffic problem (if any) which would remain? These improvement works now under way have been justified previously as the basis for a solution to current and immediately foreseeable (i.e. related to the Northern Gateway development) problems; the consultation documents provide no assessment of the likely effects of these works, and hence no clear explanation of precisely what ‘problems’ the proposed options may be attempting to resolve.
If the ‘problems’ are ones expected to arise at some future date then why, when and by how much? What assumptions underlie the projections involved in relation to:
a) national (i.e. longer distance) traffic?
b) local development and travel generated within West Oxfordshire and Oxford City?
c) the modal split of trips to and from Oxford City?
Are (b) and (c) consistent with the practical capacity of the highway network in the Central Oxfordshire area in general and Oxford City in particular? What assumptions have been made about the nature and impact of measures to reduce the proportion of single occupancy cars and to increase the use of more sustainable modes as anticipated in LTP4?
Why is there not a single mention of the modal split to cycling? Encouragement of cycling is consistent with national, and, indeed, Oxfordshire County Council’s own public health policies. The distances involved between Witney, Eynsham and Oxford are also consistent with the programme of provision of fast, inter-area cycle links established elsewhere in Northern Europe. Numerous examples can be seen both ‘as implemented’ and in policy, for instance in the Netherlands, Germany, and Denmark – see: http://www.ecf.com/wp-content/uploads/Factsheet-FAST-CYCLING-ROUTES-15.pdf .
Why is there no reference to the well-developed proposal for encouragement of cycling on the alternative B4044 route from Eynsham to Oxford station, via Botley?
The consultation material provided highlights the fact that 92% of trips on the relevant section of the A40 are generated from within West Oxfordshire and 70% are destined for Oxford City. It should be pointed out that this data is now somewhat historic, and does not reflect recent developments, perhaps most significant of which may be the opening of the new Oxford Parkway rail station south of Kidlington. Despite the potential obsolescence of the data, and the fact that Oxford destinations include a range of sites across the city administrative area, it greatly aids identification of an appropriate solution since it is both highly desirable and eminently practicable that a substantial proportion of trips to many destinations in or adjacent to the city could and should be made in whole or part by modes other than the car. The imperatives for this are the very substantial adverse environmental, social and economic effects, globally, nationally and locally of widespread and increasing use of the private car. It is illogical to consider any measures which have the potential to increase private-car use in the face of mounting concern about such effects, whether they be related to atmospheric pollution, noise, environmental amenity, mental health and well-being, or productivty.
In this context it is illogical and contrary to the Council’s own policy objectives that it should suggest the dualling of the existing highway as an option. This would increase rather than reduce the volume of car-borne trips from West Oxfordshire into and through Oxford City. Even if the additional parking demand in the city could be accommodated (itself contrary to long-established policy) the putative time-savings for motorists on the A40 Witney-Wolvercote section would be countered by additional delays and environmental detriment in Headington and other parts of the city – dis-benefits which would be experienced by a much larger number of residents and road users. The suggestion that dualling might also need to be accompanied by a revival of the ‘Tin Hat’ Northern Bypass scheme (and expenditure of an additional £100m) implies that the traffic growth already allowed for in the roundabout improvement schemes at Wolvercote and Cutteslowe would be exceeded – a scenario which would be completely unacceptable and could readily be avoided by adoption of any of the alternative options.
The options to be considered beyond the already-committed ‘do-minimum’ should therefore be confined to the various schemes centred on public transport, and encouragement of cycling. It would aid useful comment if information were provided on the main incremental benefits (and any dis-benefits) that would arise for each option relative to the do-minimum base. The consultation is also unclear on what measures are assumed to accompany works on the A40 itself which could have a major influence on their overall impact – for example in the case of the tram whether, how and when the line might be extended into the urban areas at either end. This issue, of ‘connections’, rather than simply the improvement of the A40 itself, is critical to the effectiveness of the entire proposal.
We would draw to your attention the analysis carried out by Peter Headicar of data emanating from the 2011 Census, relating to commuting patterns around Oxford, and contained in his own contribution to this consultation. This provides a much clearer picture of the likely effectiveness and consequences of any of the options presented; the consultation would be more meaningful if such an analysis had been provided by Oxfordshire County Council at the outset, and great credit is due to Mr Headicar for carrying out this exercise.
Key points of this analysis are that:
It is difficult to identify specific public transport improvements which might increase commuting patronage of these modes sufficiently to reduce future road traffic growth on the A40, given the already-committed investment to remove the bulk of present congestion. In practice, parking/traffic restraint measures, land use planning and public transport network integration are likely to have more significant effects than further investment in very expensive public transport infrastructure.
The putative case for investing in light or heavy rail solutions depends entirely on what other proposals may be made for the introduction of trams or trains in the Oxford area. This is clearly a much more complex issue than the comparatively simple business of building or re-building a rail line between Witney and Oxford; what might be desirable as far as access to or from West Oxfordshire is concerned depends on an agreed strategy for Central Oxfordshire as a whole, not the other way around!
Given commitment to the Local Growth Fund bus lane scheme and the fact that bus lanes can be extended along the A40 to the edge of Witney largely within the existing highway limits then the bus lane option seems to be clearly the most practicable and cost-effective short or medium term aspiration (possibly coupled with a further P&R site at Shores Green). It also has the advantage of the potential for services being able to continue at either end to serve directly a large proportion of passengers’ origins and destinations within Witney and Oxford and to provide a through service from Carterton. The right of way created along the A40 would both protect and allow the option of future conversion to tram operation when and if circumstances became favourable for this.
As against this option (which could be delivered in stages) the alternative of a busway or tram along a separate alignment does not appear to offer significant additional benefits at this time to justify the substantial extra cost, owing to the limitations on providing seamless and convenient end-to-end journey facilities. In fact a tram would provoke some dis-benefits if (unlike a bus-based scheme) no through services were available beyond Oxford City Centre, or from West Witney and Carterton. If bus operators continued to provide through services from these places then potential patronage on the tram would be diminished.
Although a heavy rail scheme is presented as a further option it is difficult to see how, in the short or medium term a new branch line to what are currently relatively small communities could claim the required funding, unless associated with large-scale future urban development strategies. Shorter-term, cost-effective and more worthwhile rail improvements are more likely to be gained from investment in existing lines, particularly along the Bicester – Oxford – Didcot spine which offers a much greater scale and range of benefits, including for freight.
A rail line to Witney would offer substantial benefits over a tram if it represented the only means of gaining access over existing tracks from the A40 to Oxford Station, it offered the possibility of extension to realistically-anticipated future developments further west, and its provision included associated infrastructure for making connections at key points on the route. However, these provisions are not considered in the current consultation, and, as it stands, the advantage of a faster journey to the station (and, by interchange, to other rail-served destinations) has to be set against the limitations of such a scheme for the bulk of journeys made solely between Witney and Oxford, particularly to the Eastern Arc. A rail station in Witney could not conveniently serve the town’s centre or the majority of its residential areas. Time savings on the rail line itself would therefore be offset by the additional time and inconvenience incurred by most passengers getting to and from the stations at either end of their journeys and in utilising a less frequent service (although there is enormous scope for enhancing provision of facilities to increase cycling in Witney, as well as Oxford, including improving access to stations and/or rail and BRT stops, which would increase the attractiveness of this option).
Regrettably, we identify very many issues which render this consultation heavily flawed. It is premature in terms of known uncertainties, such as the significance of the forthcoming review of the Oxfordshire Strategic Economic Plan. It is also premature in terms of the ongoing preparation of Local Plans which will determine future land-use development, and it is premature as far as the development of any properly-coordinated strategic development plan for the whole of the Central Oxfordshire region is concerned, something which we have repeatedly called for – see: http://www.oxfordfutures.org.uk/wp-content/uploads/documents/Oxford_Futures_Full_Report.pdf
The consultation also fails even to present adequately the rationale for consideration of ‘improvement’ of the A40 corridor west of Oxford in the context of Oxfordshire County Council’s recently-adopted Local Transport Plan 4, or its component parts, including the improvements to key points of constraint on the A40 corridor to which commitment has already been made, and some of which are already being implemented.
The consultation material is seriously deficient in regard to the volume and detail of the information provided and on which lay members of the public are asked to form opinions. In preparing this response we have identified a number of key questions which require answers if meaningful consideration of ‘solutions’ is to be given. As it is, not only is the value of this consultation seriously limited, but it is not even clear whether these questions have been properly considered in the preparation of the consultation.
Notwithstanding these criticisms, as for a ‘solution’, although the justification for any of the listed options is not adequately demonstrated, of those options presented the dedicated bus lanes scheme would appear to have the most merit in the short-to-medium-term, on the basis of economic, environmental and social cost-benefit.
The option of dualling the existing single-carriageway would run counter to many national and local policies, and would have unacceptable corollaries and consequences in terms of costs, and social and environmental damage, not all of which have been identified in the consultation documents. This is thus clearly not an option which should be pursued.
Chairman, Oxford Civic Society