Representation by William Davies
- Date submitted
- 30 October 2023
- Submitted by
- Members of the public/businesses
Transport and Highways I strongly object to the proposed substation at Oakendene/Kent St because Rampion have failed to take account of the volume of traffic travelling along the A272 East of Cowfold and has ignored the high number of accidents along this hazardous stretch of A272, running parallel the Oakendene site. The data simply ignores the existing consistent traffic congestion that extends from the centre of Cowfold village, past Oakendene towards Kent Street. This is possibly due to the two mini roundabouts in the village, and the volume of traffic. We have scrutinized the documents published by Rampion and noted that many pertinent questions raised by National Highways, WSCC and HDC, have not been addressed. They often redirect the reader to other chapters, or appendices, that fail to provide relevant answers. Rampion possibly assumed that this would be a “tick box” exercise, and that you would not check the data. Rampion failed to provide the relevant traffic information relating to the A272, East of Cowfold towards the A23, there is no traffic modelling, no up to date road traffic accidents (RTA), or any mention of the impact that their proposal will have on the surrounding lanes. As a consequence of omitting such significant information, their conclusion is that the proposed substation at Oakendene, will have “negligible” consequences. By way of a recent example, on Friday afternoon (20/10/23), there was another accident on the A272, which effectively blocked one lane for 48hrs. As a result of this incident temporary traffic lights were installed and drivers took alternative routes to avoid the long queues. They used Picts Lane and Kent St, as a cut throughs, which resulted in absolute chaos, caused another accident and cars ending up in ditches. A report of this, together with photographs will be in the County Times and Sussex newspapers this week. The newspapers appear very receptive to these local stories, so we have agreed to keep them up to date with developments. This incident lasted a mere 48hrs, causing chaos in the lanes, resulting in some very angry exchanges between drivers. Rampion’s proposal is expected to take five years. Please bear in mind that Rampion 2 is substantially bigger than Rampion 1 and Rampion 1’s substation should have taken 18 months, but instead took 72 months. This is not a short term problem. In addition to the unaddressed questions, it is concerning to discover a number of omissions of significant factors in their document 6.2.23- 004866046-01. 1. It is disconcerting that the main road connecting East to West Sussex, the A272, which carries about 18,000 vehicles daily, from the A23 to Cowfold village, seems to have been excluded from Rampion’s analysis. This stretch of road, from the A23, to the proposed substation site at Oakendene in Cowfold, is stated to be Rampion’s primary route, yet no relevant data appears to have been provided. Notably, there is data from West, South and North, but not from the East of Cowfold, the main proposed route. . 2. Rampion has neglected to incorporate recent pertinent Road Traffic Accidents Data for this hazardous stretch of road, known to be an accident hot spot, with one of the worst records in the region. In addition to normal traffic, this stretch of road will have to cope with thousands of Rampion’s HGV’s and LGV’s entering and exiting daily from two closely connected sites. By excluding this relevant data, Rampion have inaccurately concluded a "negligible” impact of their proposal. Interestingly, they have included data from other road sections, covering periods of lockdown, which are not representative and provides a misleading picture. There have been about 50 reported accidents in recent years, along this hazardous section of the A272, which runs parallel to the Oakendene site. A couple occurred when there were road works in place and temporary traffic lights installed. Simply drive along the road, and you will see several gaps in the hedges where vehicles have crashed through. Please note, that the number of accidents are significantly under reported, as not all accidents are reported to the police and so won’t be included in the official RTA data. There are many accidents that occur on the surrounding lanes, which are not reported to the police, and so are not in the official numbers. Picts Lane suffered two accidents this past weekend alone, one involving a horse box and another a van. These were due to the diversion on the A272, neither were reported to the police. I’m not sure if any accidents occurred along Kent St this past weekend, but they also suffered complete mayhem. There was a head on collisson involving two cars yesterday, along Spronkets Lane, that was also not reported to police. 3. The increased risk of accidents when drivers become frustrated, as outlined in the RSK Environment Ltd report of 2012 (Chap 29-22), is likely to cause more accidents and additional congestion and backlogs. 4 There is no analysis or sufficient comment about the effect of the increased traffic through Cowfold village, posing a danger to young pedestrians. With a significant rise in HGV’s and LGV’s, especially during the two year “peak period”, families with young children walking from the housing estate along the very narrow path through the village to the primary school, will be particularly vulnerable. Although this danger was raised by the Parish Council years ago and a report published, apparently, there is little that can be done due to the proximity of the pavement and cottages. 5 Another area of confusion arises from data provided by Rampion. The number of HGV’s and LGV’s appears inconsistent from one document to the next, causing considerable confusion and a lack of clarity, as to which data to accept. Much information appears to be missing or simply not included resulting in skewed or misleading conclusions. 6 There appears to be no analysis or traffic modelling for the impact of the increased congestion, on the surrounding lanes used as cut throughs. Highways England have stated “the over reliance on “A” roads in the regions means congestion is quick to develop, with no built in resilience, and in turn, pushing road users into single carriageways.” This is precisely what occurs in Cowfold, causing chaos and havoc to surrounding areas when there are roadworks or an accident. This weekend (20/10/23), there was another accident on the A272, between Picts Lane and Spronkets Lane. The vehicle could not be moved for 48 hrs, which meant that Highways installed temporary traffic lights along the A272. It is no exaggeration to say that it caused absolute chaos on Picts Lane and Kent Street. There were cars trying to go in both directions on these single track lanea, cars got stuck in the ditches, there was a horse box that rolled over, a van was involved in an accident and there was much abuse from very angry drivers and residents. This was only one weekend of utter mayhem, not several years. One of the neighbours took video footage of the extended queues and grid lock along Picts Lane, while other neighbours took photos along Kent St. The verges became a quagmire and a complete mess. Please let me know if you would like these photos and videos. 7 According to a Parliamentary Publication, the Select Committee on Transport’s seventh report, stated that “traffic diversions could have a significant effect on road safety as traffic moves to less appropriate routes for high vehicle flows”, which can have a very significant negative effect on less suitable surrounding lanes. If the substation is located at Oakendene, and traffic backs up towards Kent Street, then drivers will find alternative routes such as the single track lanes of Picts Lane, Bulls Lane, and possibly Long House Lane. There are a number of residents who use these lanes on a regular basis to move their horses to fresh pasture and turn them out. Aglands farm is a prime example of a farm being used for a variety of different purposes by a number of different people, including for the local shoots and ploughing competitions. These single track lanes are in areas of outstanding natural beauty, and have very few passing places and are not suited to heavy volumes of traffic. Picts Lane has two narrow bridges which effectively act as width restrictors. They experience grid lock if there are accidents or roadworks along the A272 towards the village of Cowfold, because drivers access the lane from both the A281 and A272. 8 There is no analysis of the existing queues that form consistently each day, during the two main rush hours, from Cowfold East, along the A272, past Oakendene towards Kent Street. The village of Cowfold is already at saturation point, when it comes to existing volumes of traffic, this can be seen by the extended and consistent queuing that occurs on a daily basis. If a traffic management scheme is introduced along this section of the road, parallel the Oakendene site, it will compound the existing congestion problems and create utter chaos for road users and local residents alike. 9 There is no analysis on the impact on the surrounding villages that will be affected, as traffic diverts to avoid the queues along the A272. 10 I believe that there was traffic analysis conducted along Kent St, this past weekend. The results will be heavily distorted, as a result of the A272 accident, so please bear this in mind. The A272 was blocked from late afternoon on 20.10.2023 until late afternoon on 22.10.2023. 11 A neighbour reminded me over the weekend, that the cyclists, horse riders and walkers frequently use these lanes. They will no longer be able to do so, since it will become too dangerous to use them, as motorists do not slow down on these narrow lanes. 12 Please also bear in mind that Oakendene is a flood plain, and if the substation is built there, that this could have repercussions on the highways, as the water is displaced by 6 ha of concrete. No such problems exist on the Wineham Lane site. It is not on a flood plane, it has two lanes and has a visibility splay, unlike Kent St.. During a meeting with Rampion at the village hall, many residents pleaded with Rampion to consider the traffic implications of locating the site at Oakendene, because they are painfully aware of the congestion that already exists on this stretch of the A272. Rampion’s answer was that this was Highway’s problem and not theirs. We would like you to investigate the data that they have supplied, much of it is missing relevant information and is skewed towards supporting their proposal. If this proposal goes ahead and is located at Oakendene, the congestion will persist for several years, and angry drivers and residents will express their frustration towards the authorities who granted permission, for this ill conceived and avoidable proposal. Interestingly, the impact on traffic congestion and RTA's, will not be as significant, if the site was located down Wineham Lane. This location is three miles away from Cowfold village, situated on a straight stretch of road and queues do not extend that far. Nobody raised the A272 traffic as an issue for Rampion 1. We also have a number of questions, to which we would like answers: 1 Who is ultimately responsible for ensuring that traffic flows smoothly along the A272 and its neighbouring lanes? Who should people contact if problems occur? Over the weekend, a number of very frustrated neighbours were scrambling to find a contact number. 2 Who is responsible for requesting and interpreting the traffic modelling information and ensuring that the underlying assumptions are correct and meaningful? 3 The authorities are aware that the A272 section of road from Cowfold to Kent St is an accident hot spot. If more accidents occur here and along the lanes, due to the proposed substation, who will be ultimately responsible? And who will be held accountable for not taking sufficient notice of the significantly increased risks involved? 4 There will be ongoing frustration and complaints from road users, businesses and local residents. Who should they contact? 5 Local authorities budgets are under pressure. However who will bear the cost of on going road management of this scheme? 6 Presumably Rampion will be responsible for covering the costs of repairing the pot holes and road damage. However this does not take into account the disruption and further delays that this will cause road users and local residents, as the roads need to be closed again for repairs. 7 The Oakendene site is a flood plain, and a number of houses nearby already suffer from surface water flooding. If the sub station is built on this site, it may well cause the surrounding roads to flood. Who would be responsible for addressing this consequential problem? 8 The data compiled and presented by Rampion has been skewed towards accepting their proposal. They have omitted significant pieces of information, including those concerning the number of vehicles using the major route of A272 East of Cowfold, (which is around 18,000) and have not included relevant up to date RTA data. There appears to be no mention of the traffic flows, which result in traffic backing up from the middle of the village, past Oakendene towards Kent St. This happens consistently on a daily basis, during rush hours of 0630 to 0900 and 1600 to 1830, demonstrating that the village cannot cope with existing levels and is beyond capacity. Therefore, the normal rule of “10% additional traffic” should not apply in this instance, as the village is already at saturation point. Now that the authorities have been alerted to these relevant and significant data omissions, who is responsible for gathering the pertinent information, assessing this situation correctly and making an informed decision that will not cause chaos and disruption for years to come? 9 At a meeting in Cowfold with Rampion in summer 2023, local residents were eager to point out the existing problems with queuing traffic along the A272 East of the village. The village simply can’t cope with existing volumes, as the traffic often extends way past Oakendene towards Kent St. If the substation is built at Oakendene, this situation will be significantly worse for a sustained number of years. This concern was simply ignored by Rampion, who said " it was Highways problem. " All this potential disruption and chaos could be avoided if the proposed sub station were located on the other suggested site, along Wineham Lane either to the South or to the North, in close proximity to Rampion 1. These alternative locations have no flood planes, or water courses, no direct access to the stream that feeds the River Adur. Wineham Lane is located some three miles outside the village of Cowfold, where the stretch of road is long and straight, and traffic seldom backs up to that junction. In the 1960’s when building the NG sub station, National Grid installed a visibility splay and two lanes along Wineham Lane for the HGV’s, which would be far more suitable option. The questions posed by the authorities have been relevant and astute, but answers have not been provided, and much of the information provided by Rampion is incomplete and hence misleading, resulting in inaccurate conclusions. Could you please investigate these outstanding questions and further examine this matter, ensuring that NPPF Paragraphs 111 and 113, and the GEART rules are applied? Thus far we have been disappointed by Rampion’s lack of engagement and inability to listen to the concerns raised by the local community. Thank you.