CORNWALL FRIENDS OF THE EARTH

Transport Campaign Group

Goss Moor

Dear Sir
A30 Trunk Road (Bodmin to Indian Queens Improvement - Order 200
HA 065/023/041

Following the publication of the draft orders and draft side orders for proposed changes to the A30 Bodmin to Indian Queens section, Cornwall Friends of the Earth (CFoE) wishes to express its objection to the scheme.

Cornwall FoE is part of the leading pressure campaign in the UK, proposing constructive solutions and creating pressure for change through mobilising public opinion and lobbying politicians and industry. Cornwall FoE comprises eight local and specialist groups including the Transport Group (CFoETG) which researches the potential for a Cornish transport policy based upon accessibility, environmental sustainability and equity.

Cornwall FoE has been actively involved in the Goss Moor/A30 process for many years and presented evidence to the Inquiry in Public in 1994. The organization has, from the first instance - and at a time when no other major bodies were prepared to so - consistently championed protection and enhancement of Goss and Tregoss Moors. CFoETG subsequently published "A30 Bodmin-Indian Queens, Goss Moor: The Case Against Dualling", in September 1998, proposing positive environmentally friendly solutions to identified problems on the stretch of road. Concurrently CFoETG has campaigned for SAC designation for the Moor. Consequently, we are gratified that proper consideration is now being given to the importance of the precious biodiversity of Goss and Tregoss Moors.

So our opposition is issue-specific relating to those areas that we believe turn what might have been a win-win situation into a gain for some areas and a considerable loss for others. Our aim is to undo this situation so that the project, as far as is possible, becomes wholly positive.

Our opposition is based on a number of different issues, but principally on the conviction that dualling of the proposed new northern A30 route would be both unnecessary and detrimental to the people and environment of both the immediate area and of Cornwall as a whole, and falls under a number of separate concerns:

Economics.
i) Economic prosperity?
Despite a somewhat generalised assumption amongst some sections of the community and especially the Cornwall County Council hierarchy that not only would a bigger road lead to more or better businesses, but that areas to the west of the route suffer from lack of accessibility due to the single carriageway, no substantial evidence has ever been presented by the contractors/consultants to support the regenerative case for such a project.

The problematic relationship between regional economic prosperity and road building is now well understood. The 1998 Standing Advisory Committee on Trunk Road Assessment (SACTRA) concluded that there is no automatic correlation between accessibility levels and levels of economic activity. Improved communications can act as a drain on resources away from so-called "peripheral" areas by increasing the possibilities of centralised production and distribution just as easily as have the opposite effect. This is by no means an unknown phenomena in Cornwall where a number of consequential relocations followed the road building programmes of recent decades[1], suggesting it would be unwise to proceed with the dualling without a clearer understanding of the consequences. Indeed, for peripheral regions, the argument that high-speed communications are essential to inward investment is self-defeating, since if being 'at the centre of things' as quickly or as cheaply as possible were so important, it would be illogical for anyone to locate far away from the centre in the first place.

Cornwall County Council (CCC) itself, observes that between 1991 and 2001, the two areas of highest economic activity were Caradon and Carrick - one to the east and one to the west of the road section; ie economic activity rates bear no relation to the A30 'problem' [2].

Transport consultant Alan James [3] was engaged by Cornwall FoE to look at evidence of the relationship between the single lane A30 between Indian Queens and Innis Downs and economic conditions in 2000 and found that "…there is good evidence that the A30 at Goss Moor has no effect on commercial property values in the west of the county, and that it has a negligible effect on locational decisions of enterprises in the area. The greatest single hindrance to development in mid and west Cornwall appears to be the lack of suitable available sites…. The key to improving economic performance in the west is to tackle the issues of land availability and dereliction simultaneously, and exploit the undoubted environmental and quality of life advantages …".

He concluded that: "[The] distorted view of what constitutes peripherality does not act as a barrier to economic prosperity in other so-called peripheral areas, and there is no reason for it to do so in Cornwall. It is perfectly possible for the Bodmin - Indian Queen's section of the A30 to be perceived as a high quality single carriageway road….".

ii) Safety
We take issue with the forecast 'savings' of £50m said to result from a reduction in number of accidents "if the new road were not constructed" (para 39 Side Road Orders). In work carried out by Alan James for Cornwall FoE in 1998 [4], the specific conditions leading to accidents on this section of the route were precisely identified and found to be predominantly site specific (inappropriate right hand turn layouts, poor funnelling from the Innis Downs roundabout, the Iron Bridge etc). That is, they were not a corollary of the single lane road itself but liable to solutions which would not need to involve the massive investment and environmental problems attendant on dualling of the entire stretch. For example, one third of all accidents could have been addressed by tackling just two junctions - Innis Downs roundabout and Roche crossroads. In contrast, just 2 out of the 108 reported accidents (monitored between 1992-96) were attributable to overtaking and could be directly addressed by dualling! Cornwall FoE consequently suggested a programme of study to investigate the potential for a much lower scale/price Route Action Plan for the area. This was not taken up so no precise financial sum or accident reduction can be arrived at. However the resultant accident reduction figures would have plainly pushed the financial savings of building this new dualled road down enormously, (despite any general improvement consequent on the higher safety attributes of dual carriageways for occupants of cars). Whilst we accept that this scheme proposal is no longer relevant, the history is of consequence because part of the case for dualling, that of an immense over £50m savings, is intensely misleading.

Traffic Induction.
i)Traffic space and management
The government has accepted the SACTRA 1994 evidence that increased road space inevitably leads to traffic generation and therefore it is only a matter of time before a road becomes congested again. This all the more so on inter-urban rural routes that have forecast traffic growths above urban areas. In Cornwall's case, where Structure Plan proposals are dependent on economic growth in a limited number of urban centres, subsequent commuting is likely to propel this increase yet further.

The Road Traffic Reduction Act requires local authorities to investigate the potential to restrain or reduce vehicle levels. The Government's ten-year plan published in July 2000 recognises the unsustainability of previous trends and explicitly rejects the outdated principle that additional road capacity is necessary to meet a growth in road traffic. It promotes an integrated transport policy, which takes account of the need to improve facilities for walking, cycling and public transport. This move away from the old predict and provide mentality has meant, crucially, that investigation of demand management options should be a requisite component of road assessment.

In this case, research into non-road and demand management options has been wholly deficient. A lack of interest on the part of public transport operators/funders was exploited by the County Council to reject out of hand any non-road options in the "Non-Car Options Study Report of January 2001(28017/OR/205). The report used only the most limited consultation to compile its findings and it's conclusion that: "… benefits to be gained by progressing non--car options as part of the A30 to Indian Queens project is that measures based on encouraging non-car trips or modal shift from the car to other forms of transport as a means of reducing traffic on the A30 will at best have only a marginal effect".

Whilst limited traffic counts, journey time and origin & destination data was gathered, nothing was done to act on some of the more positive findings. For example, in the HA's own roadside Information Surveys [5] of 1999 a considerable number of vehicles were found to be travelling between a modest number of origins/destinations. Just one instance: of 559 trips from Truro to 6 destinations of varying scale and distance (Bodmin, Exeter, Launceston, Liskeard, Plymouth and Withiel) far over half ended in just two of these destinations (Bodmin - 120 and Plymouth - 212). Nothing was investigated of the reasons for these journeys, reasons for modal choice, frequency of those particular trips etc. The HA didn't find out how many of the cars were service vehicles, how many of the commuting drivers would use their vehicles during the day; what number were single or low occupancy or had access to free or subsidised car parks at their destinations.

With some of this information it would have been possible to investigate green transport plans in dormitory settlements, at workplaces, industrial sites and in destination towns/cities; better and more applicable public transport (eg commuter routes, timings and vehicles designed to appeal to white collar workers); appropriate car parking strategies. But no effort was made on any of these matters despite unremitting nagging on Cornwall FoE's part! Similarly, there was no addressing of demand management options such as green commuter plans, car share, demand responsive initiatives separate from the HA journey data.

During this same period when the Highways Agency was refusing to countenance this research, it had its own programme of "Encouraging Travel Changes" from road to rail, which confirmed that the three pilot projects involved "… have an important role to play in highlighting the unsustainability of the current transport system. Soft approaches to behavioural change are a vital ingredient of the package of measures required to encourage more appropriate use of the car" and that: "it is in everyone's interest to promote alternatives to the car". Everyone's, it seems, with the exception of the people of Cornwall

We found it, at the time, and still do, quite reprehensible that a conclusion could be reached of an inability of non-road options to effect modal transfer or reduction when such a clear lack of effort and vision had been employed. We consequently consider that no case for more than doubling of capacity could possibly be justified without a comprehensive re-evaluation of non-car options.

ii )Climate Change
The more than doubling of road space inherent in this scheme will manifestly lead to traffic augmentation and to resultant increases in carbon dioxide emission and the dire consequences of global climate change etc. The UN's Intergovernmental Panel on Climate Change (IPCC) warned in Shanghai, January 2001 that that global climate change is likely to be much more severe than previously feared and temperatures could rise by almost six degrees between 1990 and 2100. Transport already accounts for a third of all energy consumption in the UK and about a quarter of all CO2 emissions - one of the main 'greenhouse gases' causing climate change. With rural transport growing at the fastest rate, if we in Cornwall are to contribute to the 20 per cent cut in CO2 emissions (government target by 2010) road traffic reduction has to play a major part.

Cornwall County Council has as one of it's 'overarching aims and objectives' (OI) in its Local Transport Plan: "To contribute to the reduction of forecast growth in CO2 and other harmful emissions from transport through management of congestion and travel demands". CCC has also stated in writing that: "…. each strategy set out in the Local Transport Plan is designed to contribute to the overarching aims, one of which seeks to address change and in particular a reduction in CO2". This scheme would consequently contradict CCC's own policy objectives.

Additionally, in the latest Deposit Draft of its Structure Plan, CCC commits itself to adopting the sustainability agenda as a 'cornerstone' of the Plan. It is preposterous to promote a scheme that will have such unmistakable effects on CO2 emission rates within this context.

Environment.
"Although the overall landscape might not be highly rated (sic) for its visual appearance it is extremely sensitive for its archaeological and historical remains and especially for its wildlife value, especially in the western zone, with many locally sensitive areas of very attractive landscape".
(Stage 2 Assessment Report: Landscape Effects, Nov 2000. SL 1216/Rep004-V1/Final)

"Although this is a large scale landscape, its remote and wild character, long views, expansive character and high density of sensitive landscape features make it highly sensitive…. The absence of built development in this area and its remote and open character means the landscape is highly sensitive to built development".
Cornwall County Council Character Area 13c: St Austell Group - Goss & Red Moors. Structure Plan Renewable Energy Briefing, June 2003

As stated above, we have pressed hard over several years for proper protection for the proposed SAC (and previously as a National Nature Reserve and SSSI's). We recognize, and are gratified that significant biodiversity gains will attach to the part-reunification of Goss & Tregoss Moors. However, the road must stand on its own merit, if it can - unnecessary destruction cannot be justified because of this specific gain.

A dualled northern route will clearly cause more environmental damage to the countryside it cuts through than a single carriageway. There will be a loss of about 98 hectares of agricultural land, 24 hectares of which is of 'the best and most versatile land' - Grade 3a. With development overtaking carrying capacity at such an alarming rate in Cornwall, defending the remaining agricultural resource is of vital importance; and with a land bank of often lower grade land, protecting Grade 3a land becomes yet more essential. CCC recognises this in its Structure Plan Deposit Draft, October 2002:
"The best and most versatile agricultural land remains an important resource that should be protected. It is, and will remain, best suited to adapting to the changing needs of agriculture and proposals to change its use will raise issues of national interest".

Despite the statement that the scheme "avoid[s] sites of nature conservation importance where possible…" it does in fact, still damage a part of the SSSI and proposed Special Area of Conservation (SAC) which is meant to be afforded the very highest level of protection from despoliation. It is not for a road scheme to alter the boundaries of such a site - this should be done only for purely environmental/habitat reasons.

Additionally, the proposal impacts on Cornwall Nature Conservation Sites - in particular Criggan Moor where the route scythes through the middle of the site causing significant land take.

The impact on wildlife and potential loss of willow carr/dense scrub, wet woodland and habitat for reptiles, dormice, bats, badgers and a variety of birds is of enormous concern.

The destruction of Cornish hedges is another area of concern; Cornish hedges have been eradicated at an alarming rate in recent decades; they are not only of import as fine habitat for indigenous flora and fauna and as increasingly important green corridors where development eradicates open space, but are crucial to the special quality of the landscape and to the cultural heritage of the region. Native species rich hedges, as found on the route, are covered by a UK habitat plan and legally protected under the Hedgerow Regulations (1997). Providing 'open views' to car occupants to what is allowed to remain of these features does nothing to protect them - indeed, it suggests a view of 'being in the landscape' which is reliant, in fact, on being separated from it and does not seem to understand that opening up views works both ways and serves in reality to further denigrate the land for those actually within it. Examples of this sort of car-user based engineering are rife in Cornwall and always result in permanent scars for both the landscape and the emotions of its local inhabitants.

Ecological impacts of traffic are felt up to 200m from a carriageway through air pollution and to a lesser distance through water pollution. A dualled carriageway would push the impact up to 80 metres further into the surrounding countryside and increase the severity of impact. Disappointingly, only computer modelling has been used to determine the theoretical impact of air pollution and no local air quality monitoring has been undertaken.

The level of access, albeit intended for 'local traffic' only, available onto various stretches of the current A30 at Tregoss indicates a usage which will counteract EN's initial expectations for the moor (the 'downgrading of the existing road to remove its divisive effect through Goss and Tregoss Moors…'; ".. the intent was for minimum use of the public highway by utility companies only"; "EN was looking for traffic free areas.."). Vehicles will still be able to use the old A30 travelling west to just past the Castle-an-Dinas road and be able to travel to and from the area to Padstow, St Columb Major etc, and traffic flows have been suggested to be in the order of 5000 to 7000 vehicles a day. This equates (on the basis of a very generous 14 hour day) to 6 or 7 cars every minute. If the forecasts of 41,000 cars in 2022 using the 'new' A30 (Side Road Orders para 37) come to pass the correlation would be of a car every 6 seconds on the road. This figure, of course, would be FAR higher for significant stretches of the daytime given that this is an average over a 14 hour day………..

Cornwall FoE is also unhappy at the unwillingness to reduce road widths, which is also likely to exacerbate excessive usage. Many roads on the Cornish highway network are less than 4metres wide and still allow full access to removal lorries (plus waste collection lorries etc). My own is 118" wide!

The organization is also concerned at the degradation of archaeological sites and the historical landscape and in particular damage to the medieval landscape of strip fields and hedges around Belowda, of regional importance. The latest Structure Plan Draft states in Policy 2 that: "…development proposals must respect local character and retain important elements of the local landscape, including hedges…and historic features that add to its distinctiveness". In its post-amble it says that: "Development must be compatible with the conservation of the historic heritage … Local features are an important element of local character and all too often these elements are lost by gradual attrition. The protection, conservation, interpretation and stewardship of the environment for future generations, is an important element in sustainable development and one in which local authorities must play a vital role through example and encouragement".

Conclusion
Most new road schemes, whatever their other merits or failings, will not impact on an SAC or other sacrosanct gems of biodiversity - or indeed go around one. This does not make them automatically suitable solutions to given problems. This scheme does. Likewise, this does not make it automatically 'apt'. It must be able to stand on its own merits, not just as 'not damaging' to Goss/Tregoss Moors, but as a positive contribution to a sane and sustainable transport network.

We believe this is most certainly not the case with this scheme proposal.

Ø The proposal is not justified because the case for dualling has not been made:
· There is no documentary evidence to suggest that dualling of the route will have an advantageous effect on the local or Cornwall-wide economy;
· It might well worsen the local economy;
· Traffic flow forecasts are based on deficient information: demand management options have not properly been investigated;
· Financial savings for safety improvements are based on misleading information;
Ø The proposal will, in more than doubling road space provide, at best, a stop-gap whilst encouraging yet further road miles and trips to be made.
Ø The scheme conflicts with commitments and policies in Cornwall and the UK to protect agricultural, natural and cultural resources, and to restrain climate change.
Ø A sensible alternative: that of a single lane design along this proposed route has never been investigated.

Because of the nature of our objections Cornwall FoE requests that a public inquiry should be held so that these matters can be resolved.

Sincerely

B.Levene (for Cornwall Friend of the Earth)

REFERENCES
[1] For eg - Colour Care of Liskeard relocated to Salisbury; St Ivel Creamery closed down its Hayle site in favour of centralised facilities.
[2] Cornwall Structure Plan Examination in Public Briefing Paper no 1, June 2003.
[3} Economic Impact of Mid Cornwall Road and Rail Investment, November 2000, Alan James.
[4] A30 Bodmin-Indian Queens Goss Moor, The Case Against Dualling, Sept 1998, Alan James.
[5] Parkman, 2000, Potential Options Report. 28017/OR/11

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