Please note this is the first draft of Sturry Parish Council’s response to the planning application for the new flyover and alterations to the road immediately around the Sturry Railway Crossing

Introduction The impact of the proposals in this application upon the Parish of Sturry will include changes in the patterns of vehicular traffic movement, changes in the way pedestrians are accommodated in the region of the Sturry rail crossing, landscape, ecology, noise levels and air quality. The impact on landscape and ecology will be principally in the area around the proposed viaduct, the impact on patterns of traffic movement, accommodation of pedestrians, noise levels and air quality will be to the whole of the residential area between the junction at Sweechgate and the proposed new roundabout where the viaduct meets the existing A28 on Sturry Road. In compiling this response Sturry Parish Council has made every effort to present a balanced view of the proposals in KCC/CA/0136/2021 and to represent the views of Parish residents.
Background A previous application for this scheme, KCC/CA/0091/2019 was refused by Kent County Council. The reasons for refusal were:

“The development makes inadequate provision for public transport infrastructure, contrary to policies T1 and T3 of the Canterbury District Local Plan, 2017.

The development fails to demonstrate that the navigation of the Great Stour River will not be compromised by the construction of the viaduct, contrary to policy LB13 of the Canterbury District Local Plan, 2017

The proposed alterations at the A291/A28 junction make inadequate provision for local traffic.”

Sturry Parish Council objected to this application. Our objection was supported by the third reason for refusal, namely, that the proposed alterations at the junction of the A291 and A28 make inadequate provision for local traffic. It was a disappointment that none of our other objections were considered material as they pointed out non-compliance with statutory requirements, good practice and guidance.

The Proposal

The original proposal has been amended to take account of concerns raised by Natural England over the impact of the scheme on the Stodmarsh Nature Reserve. This has entailed minor alterations to the management of water run-off and ecological mitigation associated with the viaduct and widening of the Shalloak Road junction The arrangement proposed for the A291/A28 junction has been amended to remove the ban on Canterbury bound traffic on the A28 turning left into Sturry village. The Environmental Statement Non-Technical Summary States

“1.4.4 It should be noted that for the new application, the layout of the link road from the A28 Sturry Road to the A291 Sturry Hill Road remains largely unchanged from that submitted in 2019 in the original planning application. There have been some minor changes to the drainage with an additional attenuation pond provided to the north of the railway, and a minor change in the extent of the red line boundary at the west to accommodate widening on the Shalloak Road. The red line boundary also now includes land for ecological enhancements.”

We are satisfied that the second reason for refusal“The development fails to demonstrate that the navigation of the Great Stour River will not be compromised by the construction of the viaduct, contrary to policy LB13 of the Canterbury District Local Plan, 2017” has been addressed by the new application.

The first reason for refusal “The development makes inadequate provision for public transport infrastructure, contrary to policies T1 and T3 of the Canterbury District Local Plan, 2017.” has not been addressed and the third reason “The proposed alterations at the A291/A28 junction make inadequate provision for local traffic.” Hasonly been partly addressed.

Impact on Sturry Parish

The table below sets out in broad terms how the various impacts of the scheme are distributed within the parish

Text Box: Figure: Plan of areas in Sturry Parish showing expected impact of the Link Road proposals

Note : The areas of the estate affected will be largely due to rat running to avoid detouring around the proposed roundabout inside the new development and to avoid the proposed traffic lights. The worst affected areas will be around the pinch point adjacent to the recreation ground and the junctions with the A291.

Table is based on knowledge of the existing situation, experience of the effect of recent and anticipated additional traffic flow through Sturry and Broad Oak from proposed new development and road building in Hersden and Herne.

It is evident from the table and plan above that the impact of the proposal varies from place to place in both type and magnitude. Considering the balance of impacts the overall impact is negative and while the proposal would benefit some areas of Sturry and Broad Oak this should be considered against the resulting environmental damage in other areas. It is clear that the chief beneficiaries are those living outside the parish whose objective is to get through the village as quickly as possible en route to Canterbury and destinations beyond. This benefit will only materialise if congestion is actually relieved and depends on KCC and CCC introducing new road infrastructure which will inevitably encourage greater use of vehicles and increase levels of noise and air pollution in defiance of all current and vitally important government targets for reducing emissions.

The Sturry Link Road, apart from relieving congestion at Sturry Rail crossing, was intended to enable full development of the Land at Sturry. The highway arrangements made have failed to ensure pedestrian safety at the point where the diverted A28 and A291 traffic leaves Sturry Hill and enters the new development. To follow a safe route up and down Sturry Hill pedestrians will need to make an approximately 600m long detour into the new development area. In all probability residents will take one of three other choices:

to chance crossing two separate major traffic streams without the benefit of any traffic controls,

to avoid walking and undertake more journeys by car or to stay at home and be isolated from the services and social contact they need.

We are disappointed that this area has not been included in the planning application and no proposals brought forward to remedy the situation. To many residents this represents a travesty of good planning which is contrary to ‘Designing For Movement’ and ‘Public Realm Detailing’ and ’Environmentally Sustainable Design’ as detailed in the KCC’s own Kent Design Guide. As the Highways Authority for this area it is Kent County Council’s responsibly to require that new development provides a safe, convenient environment for pedestrians.

3.4.2 A footway is present on the western side of the A291 Sturry Hill until the junction with Sweechgate to the north of Sturry. The footway is of reasonable width and of fairly good quality. Close to Popes Lane there is also a footway on the eastern side. No formal crossing facilities are located here but just north of Popes Lane are dropped kerbs and an island refuge which provides a crossing point to access the bus stops further north on either side of the road. For bus passengers walking from the north to these bus stops, it is unlikely they would walk past the bus stop in order to cross at this location.

Public transport

The reasons for refusal are not specific about which aspect of public transport infrastructure provision is inadequate. Those who attended the KCC Planning Committee of 9^th March 2021 will be aware that this was in relation to lack of any bus lane on the coast-bound carriageway of the viaduct, reasons for needing this were given at the Committee meeting. This lack of provision has not been addressed in the new proposal. In addition the proposal needs to consider the railway infrastructure at the Sturry level crossing since this is responsible for the high levels of peak time congestion at the junction of the A291 and A28. We acknowledge that the new application includes a briefing note on the situation and possible future plans of Network Rail. We disagree with the conclusion of this Note that the timescale for future improvements makes a case for building the Link Road, it especially doesn’t make the case for the proposed changes to the junction of the A291 and A28.

Sturry Level Crossing – junction of the the A291 and A28

Fig 17 in the Transport Assessment shows that capacity of level crossing is not currently exceeded and while there are delays, especially at peak times, the length of these delays could be significantly reduced by modifications to the platforms and signally at the rail station.

Recording traffic flow only goes up to 2015 so there is currently no measurement of traffic flow. We note that the intention is not to alter this junction until after the Link Road and development in Sturry and Broad Oak is completed. The traffic flow needs to be measured again and a further assessment of the crossing capacity made when this development is completed and the improvements to rail infrastructure have been implemented. Only then should a decision be made as to whether the alterations to this junction should go ahead. We therefore ask that if this application is granted it is subject to a condition which requires implementation of the junction alterations to take place only after improvements in the rail infrastructure are completed and subsequent new traffic assessment carried out to test their effectiveness in reducing congestion.

The reasons for this are:

As things stand the design of the junction allows traffic to turn left from the east-bound A28. This is a welcome improvement, however, the introduction of traffic lights introduces possibly insurmountable difficulties in bringing the signalling and crossing closures into sync to avoid sequential delays, in both directions, to traffic needing to use the crossing.

Inconvenience to pedestrians caused by the need, in some instances, to operate four sets of pedestrian lights will be a severe deterrent to use of the formal crossing arrangements and will encourage pedestrians to take the far less safe option of crossing during gaps in the traffic. The poor pedestrian arrangement supposedly to improve safety is likely be counter-productive. Daily essential journeys by pedestrians are the ones that matter. The 2017 traffic census at the level crossing records a weekday average of pedestrian movement over the crossing of 725, (Design and access Statement June 2021) This approximates to the number of people who will daily have to negotiate an arrangement which will profoundly affect their ability and willingness to undertake journeys on foot and their confidence in doing so.

Traffic travelling west along the A28 will no longer be able to U turn to access the Co-Op car park. This is a very well used route at the moment and its removal will deter continued use of the Co-Op by some of its current customers, this in turn will affect the viability of the shop and put one of our most vital retail facilities at risk. It will also encourage more traffic through the residential estate as customers of the Co-Op coming from the east will tend to divert in order to approach the shop from the north.

The same problems will be experienced by residents of Sturry court who will no longer be able to access their homes from the east.