CORNWALL FRIENDS OF THE EARTH

Transport Campaign Group

Goss Moor

Link to letter of objection of 22nd June 2003

The route has been described by supporters of its upgrading to a dual carriageway as a 'bottle neck' or as the 'weakest link' on the A30. This characterisation of the road as an unmodernized, restricted capacity section between two high speed sections, colours much of the support for dualling.

In 1994 a public enquiry 'conference' was held in Cornwall to consider "options for overcoming traffic problems" between Bodmin and Indian Queens. Cornwall FoE Transport Group argued for non-dualling options at the conference, but the conference concluded that a dual carriageway road was needed, and that the preferred route could redirect a local branch railway line between Par & Newquay and utilize the track bed where it runs parallel to the road.

Following the 1995 government review of trunk roads, work on the scheme was put on hold. In July 1998, following a further comprehensive review of the trunk road programme, the government announced that preparatory work could re-start. In September 1999 Parkman and the environmental consultancy RPS were appointed by the Highways Agency (HA) to investigate options for removing the bottleneck as part of the government's "new approach to appraisal".

The main arguments put forward to promote the upgrading to dual carriageway are:
· road congestion, particularly at peak flow times;
· economic importance to Cornwall as a 'peripheral' region;
· specific highway problems, notably the sub standard height of a bridge carrying the Par -Newquay railway line;
· redistribution of traffic onto unsuitable minor roads, in particular high vehicles avoiding the bridge, but also other vehicles avoiding peak congestion traffic;
· poor safety levels on the existing road.
These arguments are backed up by assertions of widespread public support in Cornwall for the scheme, yet little evidence exists to back up many of these perceived problems and the public's enthusiasm for dualling may result from the fact that this is the only solution they have ever been offered by the authorities.

Congestion
The consultation process is, after many years, addressing some of the glaring gaps in knowledge. An almost total lack of data has made it difficult to assess the actual evidence for the type, siting, duration, and extent of congestion, and indeed, to define exactly what is meant by the word.

Moreover, it has not been demonstrated that the single carriageway is the cause of congestion, far less that it is the only or even the main cause of congestion. Traffic queues are likely to result from the roundabout at Innis Downs, behind waiting right turning vehicles at minor road junctions, from confusion at the low bridge, or from accidents; none of these require a full blown dualling of the entire road to correct or minimise the effects of congestion.

Economic Need

The relationship between regional economic prosperity and road building is increasingly questioned, and is becoming particularly discredited in the case of so-called peripheral regions. The 1998 Standing Advisory Committee on Trunk Road Assessment (SACTRA) Report has crystallised current thinking on the subject, and concludes that there is no automatic link between accessibility and levels of economic activity [1]. It is increasingly recognised that improved communications act as a drain of resources away from peripheral areas by increasing the possibility to centralise production and distribution.

A recent study was quoted by the SW Regional Development Agency to suggest that 1300 or more jobs would be created in mid and west Cornwall as a result of the dualling. This conclusion would seem to be based on little more than anecdotal evidence from local businesses and the supposition that if the A30 was dualled, growth rates in the west of Cornwall could be expected to increase at a rate equal to half that of growth rates in the east of Cornwall, over a similar time period to that of European Objective 1 funding.

As a basis for forecasting the job creation effects of road construction this is something of a non- starter; in effect it says nothing more than that if an arbitrary target is reached then 1an equally arbitrary number of jobs will have been created. At a more fundamental level, however, it would be preposterous to suggest that the difference between east and west is attributable solely or even mainly to the presence of a six mile stretch of single carriageway road between the two. If indeed travel time and by extension cost really matters in economic decisions, it would be illogical for anyone ever to locate into peripheral areas; the west would be doomed to be remote and disadvantaged compared with the east, and Cornwall would be doomed to be remote and disadvantaged compared with Devon, and so on.

There is no evidence to suggest any deterrent effect of the single carriageway on tourism. On the contrary, Cornwall has a long history of bottlenecks at holiday periods, and an equally long history as a popular and overcrowded tourist destination, which strongly suggests that Cornwall's attractions outweigh possible delays in getting here.

Highway Improvements
None of the specific problems along this section of the A30 - the low bridge, junction layout, bends etc depend on a dual carriageway scheme for their solution. Anything that can be done as part of a dualling programme can also be done without dualling the whole road, and at lower overall scheme cost and level of environmental impact. The road could be the subject of a "Route Action Plan" as a channel for funding - facilitating faster action at specific sites, where possible, to alleviate problems for local communities.

Problem sections of the road would be tackled individually as part of an overall programme. For example if the case for re-routing the branch line is as strong as is made out, it can take place and the low bridge be removed; there is no compulsion to put a second carriageway on the track bed, and if the rail line is not re-routed the problems of the low bridge can be tackled for example by lowering the road, raising the bridge or replacing the bridge.

Redistribution of traffic
There is little information on the vehicles deviating from the A30 and their reasons for doing so. Assumptions that many of the lorries are too high to navigate the iron bridge are just that. The consultants say they will not research the number of actual high sided lorries; the number of private cars deviating to avoid presumed hold-ups; start/destination points for lorries and cars etc. Whilst the problems of redistributed traffic could largely be solved by Route Action planning (as above), this information is vital to define the prime options.

Accident Records
It is claimed that the A30 Bodmin-Indian Queens stretch of road has a poor safety record, yet Cornwall County Council statistics suggest otherwise [2]. The latest available figures, for the two years 1997 & 98 indicate 45 injury accidents. During this period there were an estimated 14,454,000 vehicle movements [3] on this stretch of road, giving an accident rate of one per 321,200 vehicle movements. The County Council favours a blunderbuss approach of reducing accident levels through dualling the entire 6 mile section of road. But because there are clear concentrations of accidents, FoE believes specific action could achieve the desired results at a fraction of the environmental and financial cost:

· Nearly half of accidents were at junctions - for instance at the Innis Downs roundabout where a quarter of all injury accidents occurred.

· Nine 'shunt' accidents occurred largely at the ends of queues of traffic (many, again, at junctions), the solution to which lies in the removal of the causes of the hold up - not necessarily by dualling.

Nature Conservation Issues
Goss Moor is the largest wetland and heathland complex in south west England. 480 hectares of the moor were declared a National Nature Reserve in 1987 and in 1988 the site, which includes Tregoss Moor, was designated as a Site of Special Scientific Interest (SSSI). The site is also a candidate Special Area of Conservation (cSAC) affording it the highest level of protection under a European directive. The Moor is home to a diverse range of endangered flora (Pillwort, Cornish Moneywort and Yellow Centuary) and fauna (notably the Silver studded Blue and Marsh Fritillary butterflies and 18 species of dragonfly; breeding birds include Curlew, Stonechat, Dartford and Grasshopper Warblers, and Snipe).

Research has shown that traffic pollution can impact on heathland ecology up to 200m from a road, so that a new carriageway on the rail bed would push the impact zone up to 80m further into the reserve.

The Department of Environment, Transport and the Regions (DETR) new Appraisal Guidance for Trunk Roads [4] makes it necessary to fully assess the environmental impact of any scheme taking into account noise, air quality, landscape, biodiversity, heritage and water. Because of the potential loss of habitat, impact on species and spread of pollution effects, it is clear that encroaching on the moor would be classed, according to the Guidance, as having a serious adverse impact or, as a cSAC, as simply unacceptable.
The current consultancy is due to be completed in May 2001. Whilst work is being undertaken on some congestion monitoring, much more is required. The appraisal process requires that attention is given to both road and non-road options. Yet insufficient emphasis is being placed on non-road options with much greater attention being given to the various proposed route options.

For instance, research has indicated a high percentage of local traffic on this stretch of road and significant concentrations of vehicles with similar start/destination points. Yet no work is being carried out to investigate complementary traffic reduction measures: car share schemes, car clubs, green commuter plans, demand responsive public transport.

Improved facilities for pedestrians and cyclists must also be considered. A third of people in the region are unlikely to have access to a car and dualling this stretch of road will do nothing to improve accessibility for non-car users such as those on a low income, children, teenagers, the elderly and the infirm - and will only serve to increase their social exclusion.

Similar research should investigate options for reducing the number of visitors to Cornwall by car, for instance through the encouragement of greater rail usage (child-friendly facilities, cheaper fares, package deals between the rail company and holiday accommodation); better local buses serving visitor attractions; holiday accommodation which arranges pick-up/drop-off services at public transport points, bicycle hire etc.

Freight traffic information is inadequate, including basic knowledge as to lorry destinations and of what percentage are travelling partially/totally empty. When attempting to quantify the economic impact of delays on the A30, there is a need to take into account the reliability of the entire journey, including non-Cornish sections.

A multi-modal freight transfer site is proposed for Cornwall, yet to date no information has been made available as to the percentage reduction of trips along the A30 (and elsewhere) which this will facilitate and its consequent impact on traffic flow figures.

Since the planning conference in 1994 CFoE Transport Group (CFoETG) has opposed the dualling proposals for this stretch of road.

CFoETG believes that:

· in line with the governments own advisory committee, SACTRA [5], providing more roadspace exacerbates traffic growth, neutralising efforts in the long term to solve congestion
· laying down more tarmac works against efforts to improve access for all sections of the communitybecause it favours private cars and road-based freight
· our country's most precious, last strongholds of rapidly disappearing wildlife and countryside must warrant complete protection

The current work being undertaken by the consultants is lacking proper research into the root causes of the problems with the greatest attention being focussed on dualling proposals.

CFoETG believes much more emphasis needs to be put on looking into non-roads options for the A30 at Goss Moor and at proper detailed research into it's perceived problems. It is simply not sufficient to base decisions of this magnitude on hearsay and anecdote or make an assumption that to be taken seriously in the modern world, a big road is better than a small one.

There is no evidence that road building guarantees economic success, and whatever happens at Goss Moor, west Cornwall will remain physically peripheral to much of the UK.

The region needs to play to its strengths and use the funding opportunities offered by Objective 1 to develop its public transport services, rail freight facilities, renewable energy resources, sustainable tourism, pollution prevention and sound land management.

The resulting stable economy should be able to deliver an improved environment and better quality of life and put Cornwall's economy several years ahead of its competitors instead of a few minutes closer by road.
à There will be another round of consultation on the proposals early in 2001. Make sure you have your say and that if you, like FoE, are not content with mere dualling options, you say so.
à Write to the consultants expressing your concerns as to the lack of detailed research, and for the need for proper assessment of all options: Highways Agency, Room 44, Tollgate House, Houlton St,BRISTOL,BS2 9DJ.
à The HA has a website: www.a30biq.co.uk Copies of the HA's newsletter and public consultation report are available from Ken Dant on 0117 987 8770
à Contact Cornwall FoE Transport Group at the address below.
à A f uller document outlining FoE's case: "A30 Bodmin - Indian Queens , Goss Moor - The Case Against Dualling", by Alan James, published by Cornwall FoE, is available from CFoETG, c/o Falmouth Green Centre,Union Rd, FALMOUTH, Cornwall, TR11 4JW.

Notes:

[1] Transport & the Economy, SACTRA,
Aug 1999, DETR
[2] AccsMap - Accident Analysis System,
Cornwall County Council
[3] Cornwall Provisional Local Transport Plan,
2000-2005, July 1999, Cornwall County Council
[4] DETR Appraisal Guidance for Trunk Roads, DETR
[5] Trunk Roads & the Generation of Traffic,
SACTRA, Dec 1994

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