Draft Parish Councils Airport Association response to the Draft Joint Local Transport Plan 4 (JLTP 4) 2019-2036
The Parish Councils Airport Association (PCAA) is a group of elected representatives from 21 parishes and one town which represent the local community interests. We cover a large area with parishes from Sedgemoor district, Bath and North East Somerset district as well as North Somerset district. The parishes the association represents are Barrow Gurney, Blagdon, Brockley, Burrington, Butcombe, Churchill, Cleeve, Dundry, Kingston Seymour, Long Ashton, Winford, Wraxall and Failand, Wrington (North Somerset)Chew Magna, Compton Dando, Keynsham Town Council, Publow w Pensford, Stowey Sutton, Timsbury, Ubley (BANES) Cheddar, Shipham (Sedgemoor).
This response refers only to infrastructure proposals surrounding the issues of an expanding airport at Bristol.
The JTLP 4 is a strategy in tandem with the West of England Authorities Joint Spatial Plan. To date an examination in public has not taken place on the Plan. The JSP has made no examination of growth proposals at Bristol Airport beyond 10 mppa. This has been confirmed in two Freedom of Information questions and in the Highways England comment to the Bristol Airport planning application 18/P/5118/OUT.
Yet the JLTP 4 looks at proposed growth and future growth to 20 mppa. The PCAA question how decisions surrounding the transport proposals are made and conclude that environmental impacts of expansion are being ignored. The PCAA recognise that the JTLP 4 does not have to go through the examination in public process but we do request clarity about the body to which a challenge can be put regarding the transport proposals surrounding the airport – is it WECA who is putting forward the Plan, or the local authority that is responsible for its delivery?
The questionnaire made available with the consultation is unsuitable for eliciting an informed response and in our view does not ask the right questions. There are no questions on environmental impacts of the infrastructure proposals and no open questions for people to give a wider opinion on the proposals.
The JLTP 4 consultation was made public on 6 February 2019. Within the document is Figure 11.1 which shows three separate corridors: for a mass transit, metro bus and a new road. On 26 February an email was received from North Somerset Council which stated that ‘any options taken forward would not be separate corridors but rather part of the same multi-modal corridor’which would contain metrobus, mass transit and a new highway. Thus three proposals within a single, multi-modal corridor rather than individual corridors. The consultation has been published with a major error, further eroding the legitimacy of the process.
A new highway was not suggested in previous consultations. The PCAA question when and why these changes have been made in such a short time span as the ‘Emerging Findings Consultation’ published November 2018 suggested only the dualling of the A38, a Metrobus and a mass transit. The JLTP 4 recognises that the reduction of carbon emissions will be minimal, the PCAA question whether there will be any carbon reductions with the inclusion of a new highway.
Why invest in a metro bus and mass transit which are promoting public transport when this is then undermined by a new highway? Can’t the metro bus run on the A38?
A mass transit and metro bus will require adequate parking in multi storey car parks on the North side of the airport to allow the communities of Chew Valley and south of the airport to access these facilities.
The multi-modal corridor is only required to support an expanding airport, which the document favours and is openly supporting even though the proposals put forward do not align with the objectives set out in Section 3, to:
- Support sustainable and inclusive economic growth
- Enable equality and improve accessibility
- Address poor air quality and take action against climate change
- Contribute to better health, wellbeing, safety and security
- Create better places (including minimising the impact of the transport network on the built, natural and historic environment.).
And the objectives of the Strategic Environmental Assessment:
- SEA 2 Reduce transport related air pollution
- SEA 3 Reduce transport related carbon emissions
- SEA 4Protectand enhance bio-diversity and ecological networks.
- SEA 6Promote human health.
Further comments are below:
- No detailed environmental impact assessment has been given for the mass transit, metro bus and new highway such as land take and loss of biodiversity
- No cycling routes have been included – the area is popular with cyclists
- No social impacts have been shown or impacts on the local communities’ health and quality of well-being as a result of the A38 multi-modal corridor
- The multi-modal corridor will be on green belt land
- No green infrastructure scheme has been shown to mitigate these schemes.
- The West of England JLTP 4 SEA published November 2018 does not take into consideration the new highway element of the A38 multi-modal corridor
- The West of England JLTP 4 Habitats Regulations Assessment published November 2018 does not take into consideration the new highway element of the multi-modal corridor on the A38.
- The West of England JLTP Health Impact Assessment published November 2018 does not take into consideration the new highway element of the multi-modal corridor on the A38.
- There are considerable risks and uncertainties to achieving any overall benefit from the JLTP 4 as it is necessary for all the proposals to be achieved for any hint of success.
- The PCAA question whether the proposal will represent good value for public money if flying is to be constrained at some point in time due to global warming
- The Plan put forward is a ‘business as usual approach’ rather than one that shows a future that is moving towards a low carbon economy
- Overall the document is disingenuous and not factual. For instance, inbound tourism is highlighted with no mention of outward tourism and ‘Bristol Airport is in close proximity [to Avonmouth/Severnside Enterprise Area] connecting the sub-region to North Africa, Europe ,the Middle East, Asia and Africa. The airport is a leisure airport; most destinations, including the most popular destinations are to Europe and the percentage of business travelers has been reducing over recent years.