North East Cambridge Area Action Plan Issues and Options 2019
Representation ID: 33501
Respondent: Mr Ben Bradnack
ECTS does not provide adequate evidence that the transport aspirations of the AAP are attainable. Consider direct A14 access to AAP area ?
Q2: Paragraph 3.6 of the Issues and Options consultation document is not agreed because this paragraph seems to assume that the AAP reflects not only that the land east of the railway is 'different in character' from the AAP area, (which it is) but that this means it can be treated as a separate entity (which it should not be, because of the issue of the only vehicular access to the area being via the Fen Road level crossing). The proposed boundary should therefore include the vehicular rail crossing on Fen Road as a material constraint on what should be permitted in other parts of the AAP area.
Para 7.6 of the consultationdocument refers to changes taking place in rail use, including increases in the north of the city which will inevitably have the impact of increasing train use of the Fen Road level crossing. These changes require consideration of alternative vehicular access to the area referred to (but then precluded from further consideration) in paras 3.6 and 4.7 of the consultation document
Current rail lobby and Lib Dem policy proposals to close the Fen Road level crossing to motor vehicles wouild leave those homes to the east of the railway along Fen Rd without vehicular access, unless opportunties are left open within the eastern section of the AAP to create an alternative vehicular access
Q3: This section fails to identify clearly the major physical constraints on the eastern part of the AAP area which are constituted by the A14, the railway, and constraining features on the south side including Bramblefields, the allotments, the current boundary with the Trinity Farm trading estate, the guided busway and the public drain, which combine to make Milton Rd and Cowley Rd effectively the only vehicular access to this part of the AAP site. These issues are referred to, but not adequately addressed in para 4.12: 'The NEC area has close connections to the A14 trunk road, and the A10, ..... Highway access to the site is mainly served via local junctions off Milton Road. Nuffield Road Industrial Estate is served fromGreen End Road. Parts of the highway network frequently operate at or nearcapacity, particularly in the morning and evening peaks with queuing and delays prevalent on Milton Road, as well as the A10 and A14, particularly at he Milton Interchange to the north'. But
These features are reduced to 'locational context' whereas they are evidently major physical constraints and should be included, referred to and addressed as such. The inference should be drawn that the eastern AAP site will suffer severe constraints on vehicular access to the site which will significantly constrain what development can take place within the AAP area.
Q4: The issues and options identified in this section fail to recognize either the impermeable physical constraints imposed on the original AAP area by the A14, the railway, the current frontier between Nuffield Rd and Cowley Park guided bus route, and the heavily used and frequently gridlocked Milton Road urban highway; or the fact that Milton Rd provides the only vehicular access to the eastern side of the AAP site Only an act of faith will persuade a reader (or, more importantly, an investor) that these constraints can somehow be addressed by more cycling and walking. Making a virtue out of such 'community cohesion' as this lack of permeability may create, appears to be making a silk purse out of a sow's ear. Paragraph 1.13 of the consultation document glosses over contradictions by referencing the Ely to Cambridge Transport study, but this Study does not address the constraints imposed by existing Milton Rd congestion, but only what would be the best development options for the AAP site to minimise transport difficulties. Para 1.13 concedes that 'the Milton Road area is already 'congested', yet it is asserted that the AAP site is 'highly accessible'. The eastern half of the AAP area is only vehicle-accessible via Milton Road. It is therefore by definition 'congested' and not 'highly accessible' . It is not clear that opening up access to the eastern side of the AAP site via Nuffield Rd would improve that situation. An earlier (2002?) proposal to access the eastern side of the site directly from a slip road off the A14 roundabout appears to have been ignored or forgotten.
The 'highway trip budget' proposed is supported 'faut de mieux', but evidence is not forthcoming that development of the eastern part of the site by any combination of residential, commercial or exployment uses can achieve the appropriate level of 'balance' that para 1.12 suggests is required. All uses are likely to have broadly the same consequences in terms of unacceptable levels of congestion unless alternative transport access routes to this part of the site are opened up.
Q5 & Q6: The 'Vision' and 'Objectives' listed constitute a wish-list of desirable aspirations which do not evidently reflect the realities, and particularly the economic or transport realities, of such a heavily constrained site. For example, Objective 5 - integration with surrounding communities - though probably desirable, is likely to be exceptionally difficult to achieve within the eastern part of the AAP area in a context which is so physically constrained, which will be subject to pressures for the community to be extremely self-contained. These constraints are likely to force a high degree of separation on the eastern part of the AAP site, rather than integration with the area surrounding it.
Q14: Cambridge Regional Colege should be a major partner in the development of the AAP site, particularl in respect of the eastern secytion which will require major community develpoment input to achieve a viable community identity, to which CRC could make a significant contribution if it chose to take that responsibility seriously.
Q17: It is important that some form of vehicular mode of crossing the railway is established from within the AAP area, rather than just the cycling and pedestrian bridge proposed in para 6.25. One option would be to establish an access route to the AAP site from the A14 roundabout, and extend this across a bridge to Fen Road . Unless that option is properly considered, it is difficult to attach significance or meaning to the point in para 6.26 of 'an opportunity to reduce the dominance of Milton Rd'. How, if not by introducing an alternative route into and through the AAP site ?. This could also enable reduced pressure on the Fen Rd railway level crossing.
Q25: The chapter on Transport in the Issues and Options consultation paper rests on extremely shaky assumptions and lacks serious supporting evidence that any of the transport proposals being considered in the AAP are attainable. The Ely to Cambridge transport study proposes that 'the development of these sites will need to deliver measures that significantly reduce the car mode share for trips to and from the area through a combination of demand-side mechanisms such as parking restraint, and investment in measures to support non-car transport'. Para 7.2 of the consultation document concedes that 76% of work trips to the North East Cambridge area are currently made by car. There may be 'a real opportunity to improve this situation'; but despite the measures in place in para 7.8, those intended or being undertaken in para 7.5, and those wider improvements listed in para 8.9, the local authorities have not established the actual sustainable transport capacity which these and any other proposed measures will provide either for the Cambridge sub-region as a whole, or for the AAP area in particular, as required by NPPF paras 102,103 and 104 . 'Ambition' such as that referred to in 7.10 in respect of the Mayor's proposals is no substitute for the evidence of what might constitute the optimal possible 'balance' that can actually be achieved in this respect
The local authorities should establish first what sustainable transport capacity exists or can exist, both for this AAP area and for the Cambridge sub-region as a whole, in line with the National Planning Policy Framework
One way to relieve transport pressure on Milton Road could be to create an access to the AAP site directly off the A14 roundabout, which could also provide a bridge across the railway which could relieve the ptressure already experienced by vehicles using the Fen Rd level crossing (see response to qu 17).
Q26: While an ambition to achieve in the AAP area a low share of journeys made by car is supported, very little evidence is presented (or indeed available for comparable developments in our region ?) that this ambition is attainable or compatible with the proposal to develop 8,500 dwellings on the AAP site. Overall sustainable transport levels have never been established on the basis of evidence for the Cambridge sub-region, and until they have been and have been shown to match both existing realities on the ground and what can be sustainable in the future, this aspiration is just that: an aspiration, not evidently attainable
Q27: The 'highway trip budget' proposed is supported. This appears to be the most serious effort that the local aiuthorities have made to 'put transport first' in the the identification of development capacity of sites - an approach which the local authorities should have adopted from the start in identifying and supporting sites for development in their most recent Local Plans by establishing overall sustainable transport capacity across the local authorities' areas and using that information to compare all possible development options.
So this approach is supported 'faut de mieux', despite the fact that evidence is not forthcoming that development of the eastern part of the site by any combination of residential, commercial or employment uses can achieve the appropriate level of 'balance' that para 1.12 suggests is required. While The Ely to Cambridge Transport Study is used to justify a particular balance of uses including substantial residental development, all uses seem likely to have broadly the same consequences in terms of unacceptable levels of congestion of Milton Rd unless alternative transport access routes to this part of the site are opened up. It is not clear why (for example) an alternative access directly off the A14 roundabout has not been given consideration
Q55 & Q56: Responses to these two questions have been linked because both appear to be premised on the same assumption about the economic viability of commercial outlets within the AAP site which are highly questionable. The physical characteristics of the AAP area, and the aspiration (derived to a large extent from that constrained characer) for 'higher levels of internalised trip-making' must surely work against the likelihood of the sort of shopping self-sufficiency which is required to - or could even hope to - 'fully meet local needs' as sought in para 10.1. The record of local shopping centres in Cambridge remaining viable is not robust. It seems extremely unlikely that commercial outlets opetrating within such physical constraints and planning aspirations can hope to be economically viable, much less to be competent to 'fully meet local needs'
Q84: The possibility of moving the activities of Anglian Water away from the AAP site, and the possibility of consolidating their activities on a smaller site, has provided a very welcome stimulus to the local authorities to consider how the whole eastern part of the site might be re-configured. Added stimulus has come from the completion of Cambridge North station, the rerouting of public transport services to visit the new station, and the recent change to enable the City Council and SCDC to act jointly in respect of The eastern part of the AAP development sites.. All this is very welcome and is supported
But the exist ing area is the mess that it is for good reasons, not all of which pertain to the Anglian Water facility being located there, significant though that presence is. Because of its relat ive inaccessibility and the impermeability of its boundaries it is a convenient place to dump less desirable neighbours The area constitutes a hostile environment in itself which invites and encourages various forms of urban detritus: ugly buildings, car parking chaos, roadway congestion, large stretches of land effectively quarantined by lack of proper controls; and transport challenges unmet..
Unfortunately changing such features as Anglian Water Company does not alter the fact that all the original external constraints on the site still apply. These will be exacerbated by any increase in vehicle use of that section of |Milton Road which governs, and is likely to govern, access to the easter part of the AAP site.
Transforming such an unattractive and inherently disadvantaged area into a model of urban regeneration on the scale proposed can only be carried out with a massive investment of financial resources. These are only likely to be forthcoming as part of a level of growth which is fundamentally unattractive to many, and to which it is not evident that Cambridge residents have so far 'signed up' .
So objections are on two broad grounds
1. The inherent difficulties and expense of what is proposed in the 'vision' can only be addressed by raising the resources from levels of urban growth on a wider canvass which local people are unlikely to wish to support
2. The local authorities have not shown that the particular transport challenges which the proposals will pose for Milton Road can be addressed, or will be addressed, until the local authorities achieve a proper understanding of what levels of transport activity the Cambridge sub-region can sustain