By kind permission of David Sawers we have below the evidence that was presented by him to all members of the Worthing Borough Council Development Control Committee.

(note the postscript at the end)

 

                        TITNORE LANE

Dear Councillor

This letter is written on behalf of the Worthing Society. Protect Our Woodland , and the East Preston and Kingston Preservation Society. Because of the limited time before your meeting on January 5th, it has not been possible to discuss its contents with them.

The papers before the Committee seek to justify the decision to approve alterations to Titnore Lane which would require the felling of 210 trees in ancient woodland, rather than introducing a 40mph speed limit and traffic management measures. This decision was taken on June 10th after the Committee had been given misleading information about the status of Titnore Lane and the feasibility of a 40mph speed limit; and similarly misleading information was given to Worthing Borough Council and the West Durrington Consortium, and incorporated in the papers presented to the Committee.

STATUS OF TITNORE LANE

Mr Lawrence Stringer of WSCC told the Committee that Titnore Lane was an A road; the same information was apparently given to the West Durrington Consortium and Worthing Borough Council and appeared in the Agenda Papers. The paper before you today states that the reclassification in 1995 should not have been undertaken until highway improvements had been carried out in Titnore Lane . An email of July 1st 2004 from Mrs Margaret Johnson of WSCC to Mr John Hughes states that the lane would not meet the criteria for an A road without improvements.

Mr Stringer, in a letter of September 1st to Mr David Sawers, wrote "I was aware of the error made by the Department of Transport in designating Titnore Lane as an A road when the Patching junction was completed". In a letter on October 4th, he justified his description of the lane as an A road by saying "My view was that to describe Titnore Lane as a C class road would have introduced an element of unnecessary confusion to the meeting".

Mr Stringer also wrote in his letter of September 1st that discussions had taken place with various government bodies over a number of years to try to resolve the situation (to get the road sign at the Patching junction altered to remove the description A2700). 

If WSCC had been discussing with government bodies the removal of the erroneous description of Titnore Lane as A2700 for several years, it may have been doing so at the same time as it was telling the West Durrington Consortium and Worthing Borough Council that Titnore Lane was an A road.   

A 40MPH SPEED LIMIT ON TITNORE LANE

Mr Stringer told the Committee on June 10th that a 40mph speed limit could not be introduced on Titnore Lane because the Council's policy for speed limits ruled out the use of 40mph limits on A roads that did not have frontage development. According to the papers for January 5th, a similar statement was made by a Cabinet member to the West Durrington Consortium; and this statement appears in the contributions to the Agenda Papers from the West Durrington Consortium and Worthing Borough Council.

There is an exception to WSCC's policy on 40mph limits on the A259 east of Littlehampton, where a 40mph speed limit has recently been introduced on an undeveloped stretch of road. WSCC states that this is the only exception to its policy, that it was introduced in response to the particular accident characteristics of the location, and that similar circumstances do not exist in Titnore Lane .

However, the West Sussex Local Transport Plan 2000 states that a 40mph speed limit had been introduced on the A24 between Horsham and Capel; in East Sussex there are 40mph limits on the A22 over Ashdown Forest and on rural sections of the A27. The A259 east of Littlehampton does not therefore seem to be unique.

The accident rate on this stretch of the A259 is almost identical to that on Titnore Lane, despite WSCC's suggestion that it is particular and different from Titnore Lane . According to Mr Stringer's letter of October 4th, there were 24 personal injury accidents on this stretch of the A259 in the three years before the speed limit was introduced and 17 on Titnore Lane in 2001-2004. Traffic on the A259 was about 16,500 a day in 2003; on Titnore Lane WSCC says it was 8,463 a day. The relevant stretch of the A259 is about 1.75km long; Titnore Lane is 2.5 km long. Accidents per million vehicle kilometres were therefore .759 on the A259 and .734 on Titnore Lane.

According to Mr Stringer's letter of October 4th, speeds on Titnore Lane are slightly higher than on the A259. The characteristics of the two roads are therefore very similar, and a 40mph speed limit would be as appropriate for Titnore Lane as for the A259. What is more, danger to vulnerable road users such as pedestrians, cyclists and riders is one reason for imposing a 40 limit; and they are in much greater danger on Titnore Lane than on the A259, which is a wider road and has a wide grass verge.

ACCIDENTS ON TITNORE LANE

WSCC has provided its calculations of the effect of a 40 limit or road improvements on accidents on Titnore Lane , and they are attached to the Worthing officers' paper for this meeting. These calculations are said to have been undertaken by one engineer in the Council's Accident Prevention Team, and take the form of two tables with lists of assumptions. It is unclear whether they are the figures used in preparing the papers for the meeting on June 10th, because those papers stated that a 40 mph limit would produce 55% more accidents than the proposed road improvements, while the figures now circulated show the 40 limit producing 73% or 80% more accidents than an improved road.

These figures reveal that the crucial assumption creating the difference between the accident rates in the two cases is that there would be three accidents a year on the approaches to the new roundabout at the entrance to the development if there was a 40 limit, but none if the road was straightened. If this assumption was removed, accidents in the 40 limit case would be about 20% higher than in the "improvement" option instead of 80% higher.  The second important assumption is that a 40 limit would reduce accidents by 10%, while bypassing the South Lodge bends would reduce accidents on this stretch of road by more than 80%. This assumption accounts for the remaining 20% difference in accidents between the two cases. No justification for these assumptions is provided.

It is alarming that so serious a decision as whether to construct a road through ancient woodland, woodland that lies within the designated boundary of the proposed South Downs National Park, should depend the validity of assumptions that have not been justified and that are not obviously plausible. Why should vehicles be more likely to collide on the approaches to a roundabout if there is a 40 mph speed limit than if there is no speed limit and the road has been straightened? They will presumably approach the roundabout at a higher speed in the latter case.

The Worthing officers' assessment of the application for meeting on June 10th rightly stated that the issue that the Committee had to decide was whether the improvements to safety attributed to the proposed alterations to Titnore Lane would justify the damage to the ancient woodland that they would cause. Now that we have seen how fragile is the evidence for benefits to road safety from the proposed alterations, the Committee may want to consider whether it needs better evidence on the effects of the available alternatives on accidents before it approves a proposal that would harm one of Worthing 's remaining natural attractions.

Does the Committee consider that it is justifiable to take a decision to build a road through protected ancient woodland on the basis of unsubstantiated assumptions about the behaviour of drivers? Could it defend such a decision on the evidence it now possesses?

We suggest that the Committee does require better information about the relative effects of a speed limit and traffic management, and of alterations to Titnore Lane on accidents before it takes a decision. We also suggest that it needs more advice on the sort of measures that can be taken to reduce speeds on a road like Titnore Lane ; more information may be needed on existing speeds on the lane.

We do not believe that WSCC is able to provide the advice and information that the Committee requires. Its recent conduct suggests that it is an advocate, not an impartial adviser on this subject.

Worthing would therefore be better advised to commission consultants, perhaps jointly with the West Durrington Consortium, to advise it on the measures that might be taken to reduce speeds and accidents on Titnore Lane , and how the effects of traffic management measures would compare with those of the alterations proposed by WSCC.

CONCLUSIONS

The policies of WSCC do not provide a plausible obstacle to the application of a 40mph speed limit and traffic management measures in Titnore Lane . The material supplied by WSCC does not provide an adequate basis for a decision to alter the road and harm the ancient woodland. Worthing should therefore seek to obtain the evidence needed to take a decision for itself. Until it has obtained this information, it should not grant planning permission for WSCC's proposed alterations to Titnore Lane .

                                                             David Sawers 

 POSTSCRIPT

The meeting on January 5th showed that there is considerable disquiet among councilors about WSCC’s  conduct – hence the decision to ask for more information about the status of Titnore Lane and the reasons why WSCC considers a 40 limit unsuitable for Titnore Lane but suitable for the A259.  In particular, councillors  requested more information on vulnerable road users and on why WSCC assumed there would be three accidents a year on the approach to the new roundabout if there was a 40 limit but none if the road was realigned. However, some councilors still regard the realignment scheme that they approved in June as a satisfactory compromise between the protection of the environment and the demands of highway engineers.

Since the meeting, I have found the Dept for Transport’s guidance on rural speed limits. It divides roads into upper tier, which mostly serve a “through” function and are  typically A and B class; and lower tier,  which have a local or access function and are typically C class or unclassified. Titnore Lane serves both functions but is more lower than upper tier. The DfT recommends 40 limits for lower tier roads where the accident rate is above 60 per 100 million vehicle kilometres and/or where it forms part of a recognized route for vulnerable road users. The accident rate on Titnore Lane is 73 per 100 million vehicle kilometres; we want more information on its use by vulnerable road users, but it is certainly used by some – who are very vulnerable in the absence of a verge. So the lane does meet the criteria for a 40 limit.

The DfT has had an Assessment Framework for determining speed limits produced by the Transport Research Laboratory, including a spreadsheet that calculates the effects of alternative speed limits if it is provided with the figures for traffic, speeds and accidents for a road. If this spreadsheet is given the figures for Titnore Lane , it predicts a 3mph fall in speeds and a 24% reduction in accidents. WSCC predicts a 1-2mph reduction in speeds and a 10% reduction in accidents. Once again it seems that WSCC has biased its results against the option of a 40 limit. We must hope that this further evidence of the unreliability of any material from WSCC.

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