The highways department at Wokingham Borough Council (WBC) have submitted a planning application to ‘improve’ the junction at Molly Millars Lane and Finchampstead Road. This junction is known as the Western Gateway to the South Wokingham Distributor Road (SWDR) which is the road that will run from Montague Park off London Road to Tesco on Finchampstead Road.
This junction has been talked about for a number of years and is part of the council’s Core Strategy. It is a key junction on an already congested road and will affect many of you reading this blog. The planning application is now open to public consultation until 1st February and listed on the planning website under application number 203535. I strongly urge those of you with an interest to take a look at the documentation and submit your comments.
I thought it useful to share my thoughts on the planning application as I’ve spent a fair amount of time researching. I fully appreciate that not everyone is going to agree, but I hope it provides some food for thought. I don’t have all the answers, but then I’m not a transport planner. I do know how to scrutinise and challenge though which is a big part of my role as a local councillor and following scrutiny of the planning application, I am objecting to the application.
I am objecting on the grounds that it goes against the following Core Policies from the Core Strategy:
- CP1 – Sustainable Development;
- CP2 – Inclusive Communities;
- CP3 – General Principles for development;
- CP6 – Managing Travel Demand;
- CP21 – South Wokingham Strategic Development Location.
It also goes against the Council’s decision to declare a climate emergency, does not help tackle air quality issues in the vicinity and, despite what the Design and Access Statement (DAS) states, is not compliant with the current government guidance in the Local Transport Note (LTN) 1/20.
Purpose of the Proposal – CP21
The raison d’etre for this proposed project is to increase capacity as a result of the South Wokingham urban extension that is to deliver approximately 2,500 new homes. The DAS actually states that “the proposal…will ensure reduced congestion and enhancement to social well-being in the area through minimised journey times.”
Average household car ownership is 1.4 vehicles per household according to the RAC and on an increasing trajectory. This equates to approximately 3,500 extra vehicles on the road network. Wokingham Borough is a high car owning borough meaning the estimation of 3,500 is conservative.
At initial consultation events, it was sold as a way of alleviating the extra vehicle movements from the South Wokingham Strategic Development Location (SWSDL). The increased size of the roundabout would allow vehicles to drive quicker and there would be two lane entry on each of the 3 arms to the roundabout increasing stacking capacity. Upon reviewing the plans, there is only 1 arm that has a decent length of two lane entry (Molly Millars Lane), the other 2 arms with very little length, which therefore does not address the problem. It is Finchampstead Road that has the current congestion issues, and according to the design drawings, it looks like an additional 4 cars at most could be stacked in the 2 lanes on both the North and Southbound approaches to the junction.
There is also the issue that the narrow bridge that serves the railway has not been addressed so there will continue to be an issue with high sided vehicles, particularly as there will be additional vehicle movements of this nature accessing the housing on the new SWSDL. The Council’s Core Strategy under CP21 actually states that “it is…important that development south-east of the town is accessed from a distributor road through the SDL to connect into the A329 east of the town and the A321 to the south. In order for this road to function effectively, it will be necessary to resolve the height restrictions at the railway bridges on the A321 Finchampstead Road.” It also states under CP10 that “improvements to the railway bridges on the A321 Finchampstead Road, Wokingham…are integral to the core strategy.” The reasons for not addressing this in the DAS are to do with disruption and cost, although the core strategy addresses the cost with S106 contributions. Not tackling the narrow bridge makes the proposed project futile.
Taking all of the above into account, I struggle to understand how this design actually fulfils its purpose and do not see how it is compliant with CP21 as there is not a significant increase of vehicle stacking, and the bridge is not being tackled. The only additional measure is the increased size of the roundabout which will go some way to helping, but not with the 3,500 extra vehicles in the mix.
If congestion really is what is trying to be addressed by this project, surely it would make sense to design a scheme that makes active travel measures safer and more appealing to reduce the number of vehicles on the road network in the first place. I believe the design team have really missed this crucial fact, because making things bigger for vehicles does not solve congestion in the long run; it increases the reliance on private vehicles so you just attract more of them to the road network. This whole project has been about cars, and consideration for alternative modes of transport have fallen by the wayside.
Alternative Travel & Safety – CP6, CP2 and CP1
I am a car driver, a cyclist and a pedestrian. I make this point because sometimes, when advocating infrastructure for walking and cycling, people think I’m anti-cars which I’m not. I use a car for journeys that I can’t make via walking, cycling or public transport. Sadly, in Wokingham, the infrastructure that would allow me to choose safe alternative modes of transport is lacking, and for many people that I speak with, having this infrastructure improved would allow them to make better choices about how they move about the area. In fact, building new roads actually increases traffic because it increases people’s reliance on cars rather than alleviate congestion.
CP1 states that development must “demonstrate how they support opportunities for reducing the need to travel, particularly by private car in line with CP6,” and CP2 states “sustainably meeting the needs of young people includes ensuring that children of primary school age have access to a school within walking or cycling distance of their home (3-4km) along a safe route.”
CP6 states that planning permission will be granted for schemes that:
a) Provide for sustainable forms of transport to allow choice;
b) Are located where there are or will be at the time of development choices in the mode of transport available and which minimise the distance people need to travel;
c) Improve the existing infrastructure network, including road, rail and public transport, enhance facilities for pedestrians and cyclists, including provision for those with reduced mobility, and other users;
d) Provide appropriate vehicular parking, having regard to car ownership;
e) Mitigate any adverse effects upon the local and strategic transport network that arise from the development proposed;
f) Enhance road safety; and
g) Do not cause highway problems or lead to traffic related environmental problems.
Local Transport Note 20 (LTN 1/20) was published in July 2020. LTN 1/20 sets out better standards for walking and cycling infrastructure. The plans attached to this application do not meet these standards despite its claims that it is. Whilst a lot of the design work was undertaken prior to the publication of LTN 1/20, it states in the road safety audit that “a previous stage 1 Road Safety Audit was undertaken in September 2020 on an earlier scheme.” Given that the scheme was redesigned after LTN 1/20 was published, why was little attempt made to make it compliant with LTN 1/20? What is even more frustrating is that the design changes made actually make it even less compliant with LTN 1/20 as crucial pedestrian infrastructure has been removed.
The DAS makes reference to following LTN 1/20 but has been selective in which sections it picks out. Rather than be led by the guidance, the designers have shoehorned in the existing design and picked out the bits of the LTN 1/20 that they can try and hang from it without taking account the overall principles of it.
The DAS says that in “Paragraph 6.5.6 of LTN1/20 states that shared use may be appropriate in some situations, if well-designed and implemented such as alongside interurban and arterial roads where there are few pedestrians, at and around junctions where cyclists are generally moving at a slow speed including in association with appropriate crossing facilities and in situations where a length of shared use may be acceptable to achieve continuity of a cycle route. These examples can be applied to this scheme.” The writer of the DAS is taking liberties here. Firstly, this is not an interurban area, but an urban area. Secondly, they haven’t listed the full text from LTN 1/20 which states it needs to be in association with toucan facilities (which as I will comment on in due course, the main toucan facility is being removed). The author of the DAS hasn’t also taken on board that the LTN 1/20 actually states that “shared use routes in streets with high pedestrian or cyclist flows should not be used.” The DAS uses existing pedestrian and cyclist numbers to claim that this isn’t a high number. Whilst looking at future vehicle numbers, the report writers must model for future pedestrian and cyclist usage (which they haven’t) and given that the climate emergency action plan demonstrates a 4-fold increase in cycling is required to be compliant, not to mention the additional usage by people living in the 2,500 properties to be built, this route is a high volume route for cyclists and pedestrians. There would clearly be a conflict with shared pedestrian and cycle users on the same path.
In addition to the lack of compliance with LTN 1/20, there is no mention anywhere of the Local Cycling and Walking Infrastructure Plan (LCWIP) which includes a route through the proposed location. Has the design team for this proposal consulted with the LCWIP team to ensure they’re working together on this or is the left hand not talking to the right hand? Surely it would make more sense to include the LCWIP design with this design rather than as two separate projects which would create more disruption and increased spending?
I struggle to comprehend why a footway of just 1.1 metres wide along the eastern carriageway of Finchampstead Road is not being tackled. There is opportunity to make this wider. It seems that this may be narrowed further given the comments in the safety audit which states that “the drawings provided detail a proposed directional sign on the eastern side of Finchampstead Road (South) visible for northbound road users. The signs posts are to be located within the eastern footway. However, no details have been provided on post details or mounting heights. It appears that both of the signposts will be located within the existing footway which will restrict the useable width and it is unclear what width will remain. Narrowing the footway may lead to pedestrians walking into the carriageway to avoid oncoming pedestrians or if a wheelchair users/pushchair is too wide to fit through which could result in a collision between a pedestrian and a vehicle.” The safety audit also states that “the width of the east footway in front of properties 92 to 100 was not increased from existing provision despite the increase in verge width due to restricted/substandard widths both north and south of the site boundary.”
On the western side of Finchampstead road, the 3 metre wide footway suddenly stops outside 89 Finchampstead Road. The footway on this side of the road is incredibly narrow, and to suddenly make it very difficult for those on mobility scooters or parents with young children to use the footway doesn’t make any sense, particularly with no controlled crossing facility and goes against CP2 which is about communities being inclusive.
The DAS states that “the controlled crossing on the southern arm of the roundabout was also removed as it was determined that there is not a pedestrian/cyclist desire line to cross Finchampstead Road South of the roundabout and due to constraints on space with vehicle accesses and lack of available width on the west footway to provide a crossing in line with design standards.” This is a complete fabrication as there is a desire line to cross at this point (which has also been picked up in the safety audit) and I’m astounded that the designers have the audacity to tell mis-truths in this manner. Prior to the submission of this application, I have already expressed to the design team the serious concerns I have for safety by the fact that a controlled pedestrian crossing has been removed on the south arm of the junction, and the uncontrolled splitter island has reduced visibility sightlines for pedestrians crossing from west to east. What the team failed to mention is that the stage 1 safety audit has also highlighted these very concerns, yet this application has still been submitted in the knowledge that there is an increased risk of personal injury.
As is stated in the safety audit from their site visit, “pedestrian flows were high, and several cyclists were observed particularly on the footway on Finchampstead Road.” Despite the current poor infrastructure, a number of pedestrians and cyclists do use this route (I am one of them). Pedestrians use the current controlled pedestrian crossing on the southern arm of the junction in high numbers. People take the shortest route to get to their destinations and asking people to walk in the wrong direction in order to get to their destination does not happen. The highways planners should be designing the scheme around what people are likely to do, and that is cross the south arm of the junction. This makes it confusing as to why the design has removed any controlled pedestrian crossing on this arm of the junction given how heavily utilised it is. People will try and cross here and the uncontrolled splitter island is not a safe substitute. Pedestrians will have to cross the west side of the carriageway across 2 lanes. Those crossing from west to east have very poor sight lines towards vehicles approaching from the south due to the bend in the road, and there has been no consideration of whether properties 89 and 91 Finchampstead Road could put up screening that could prohibit this further (such as trees or a fence or wall). For all users crossing over the eastern carriageway, traffic coming off the roundabout will be at a higher speed to what it is now (the whole point of the design), and given the high volume of continuous traffic, there will be little opportunity for pedestrians to cross, resulting in them taking a chance. This will lead to either a pedestrian being struck by a vehicle and/or a pile up with vehicles suddenly braking.
The reason used of not having enough width on the western footway to accommodate a formal crossing is something of a mystery as well because prior to these revised plans that did include a controlled crossing, this was being accommodated by purchasing land from a property on the western side in order to widen the footway. This land is no longer being purchased and now the formal crossing isn’t in the plans. May I suggest the design team have a serious rethink because they are compromising people’s safety.
The safety audit picks up on my concerns stating that “the drawings provided show the removal of the existing signalised crossing on Finchampstead Road (South) and replacing with uncontrolled crossings via the splitter island for the proposed roundabout. Several pedestrians were observed using the crossing at the time of the site visit and removing this facility may increase the likelihood of a pedestrian/vehicle collision if pedestrians have to use the uncontrolled crossing instead.”
It also goes on to say that “the drawings provided show a proposed uncontrolled crossing on Finchampstead Road (South) via a new splitter island. For pedestrians on the western side of Finchampstead Road waiting on the tactile paving wanting to cross, visibility to the right is limited which could lead to pedestrians starting to cross the road before they can see an approaching vehicle from the south. This could result in pedestrian/vehicle collisions resulting in pedestrian injury.”
What I would say is that it is nice to see the correct coloured tactile paving being used at the proposed crossings in this design, unlike the marketplace.
I am also concerned about the properties in the vicinity of the proposed junction and how they use their driveways. The safety audit highlights that “the drawings provided details of an access point to the eastern side of Finchampstead Road on the approach to the roundabout from the northern arm. Previously a turning head had been included as part of this access to allow vehicles to enter and exit the carriageway in a forward gear. It is unclear whether the property gaining access from this access road has space for vehicles to turn around within its boundary. The problem arises if a vehicle cannot turn around, this may lead to vehicles reversing onto Finchampstead Road, where there are now two lanes of traffic, which could result in a side impact collision with a vehicle on the roundabout approach.”
This concern has not been addressed in anything I can see, and in addition, despite me contacting highways to question this, the shared driveway for properties 94, 94a and 96 Finchampstead Road is not even shown on any of the designs, let alone any consideration as to how they might use the driveway given its proximity to the junction and in particular the south arm splitter island. I would like to understand how these residents are expected to utilise their driveway.
I am deeply concerned by the safety audits comment that “the Audit Brief states that one Departure from Standard has been identified and is due to be submitted for approval for a reduced visibility on approach to southern entry to CD 116 para. 3.39.” I believe this is the poor visibility for the south arm given that the new design no longer uses land from 89 Finchampstead Road. I would be interested to know exactly what this reduced visibility is, why it’s going into the designs and what consideration has been given to mitigate against it.
Looking at the visibility analysis coming from Finchampstead Road South, it looks at the Safe Stopping Distance (SSD) for the give way line and the junction itself, not the uncontrolled crossing that precedes it. Given that the speed of approaching vehicles further back will be quicker, and there are already sight line issues that I’ve raised above, this needs to be modelled.
In the visibility analysis for Finchampstead Road North, the forward visibility only takes into account smaller vehicles that can approach in their lane. There is no consideration of large vehicles that will be entering down the middle of the highway. The visibility from this arm of the junction of pedestrians using the uncontrolled splitter island on the south arm is measured from the give way line. Given the ‘quicker’ nature of this roundabout that we are promised, surely consideration should be given to those approaching the roundabout from further back who don’t need to stop at the give-way line who will speed up and have a longer SSD.
The Molly Millars Lane entry forward visibility SSD on approach is taken from the left hand lane (the carriageway has split into 2 lanes at this point) and goes to give way line. How will someone in the right hand lane see someone waiting at the splitter island crossing from the north and vice versa?
Flora and Fauna – CP3
CP3 states that a development must “maintain or enhance the ability of the site to support fauna and flora including protected species.” The design has multiple trees to be removed, including TPO’d old oak trees. Just 11 new trees are being proposed to replace the numerous established trees being removed. This is completely at odds with the council’s commitment on tackling climate change. What is being done to mitigate this destruction?
There are to be some green areas around the junction where grass is being sown. Is this not an opportunity to look at wildflower planting as well to increase local biodiversity?
Air Quality – CP1
CP1 states that a development must “minimise the emission of pollutants into the wider environment” and “avoid areas where pollution (including noise) may impact upon the amenity of future occupiers.”
I am extremely concerned by the air quality report attached to this application. It only looks at Nitrogen Dioxide (NO2) and Large Particulates (PM10) stating that “road traffic can make substantial contributions to PM2.5 concentrations at the kerbside (within 1 m of the kerb), but at the roadside (a few metres from the kerb) the contributions are relatively limited. Given that none of the receptors are located in close proximity to the modelled roads (all being at least 50 m away), PM2.5 is not assessed in this report.”
PM2.5’s (small particulates) are attributable to 80% of deaths from air pollution, so to not consider their impact on a scheme like this is disgraceful, particularly in light of the verdict of Ella Kissi-Debrah’s tragic death. This route is used by school children and air pollution is incredibly damaging, stunting lung growth. In fact, Wokingham is above regional and national averages for children hospitalised for respiratory tract infections, so to not consider the biggest concern when it comes to air pollution is negligent. The reason given for not considering it as stated above is because the monitors are not at the kerbside. The monitors being referred to are not PM2.5 monitors but NO2 diffusion tubes so that’s got nothing to do with it and they also don’t consider those that are kerbside such as pedestrians and cyclists. This reasoning for not measuring the impact in terms of PM2.5’s does not stand up.
Currently, the borough of Wokingham has no PM2.5 monitors, although this is set to change. PM2.5 can be modelled using the Defra data from the AURN site in Reading, which is what is used to model PM10’s (which the report writers clearly had no problem doing). The British Heart Foundation have done modelling for this area and the levels of PM2.5 from the modelling are in breach of World Health Organisation (WHO) levels already, without taking into account increased traffic. Whilst the report states that cars will become less polluting with newer technologies, PM2.5 is a pollutant that doesn’t just come from the engine but from break and tyre dust, and even from the materials used to build roads. In fact, 75% of PM2.5’s don’t come from exhaust emissions. With the trajectory of car ownership going up (and the building of more roads just exacerbates this), the fact that we’re already in breach means more needs to be done to mitigate this, and that is reduce the amount of traffic on the roads, not make roads bigger to accommodate more cars. It’s counterintuitive.
The argument will be that the legal limits and WHO limits are not the same (the UK government allowing for 2.5x the amount of PM2.5). Firstly, the government is wrong on this (many countries including Scotland have adopted WHO limits), and WBC has a duty to the community it serves. Wokingham residents die every single year from diseases attributable to air pollution. Secondly, the government is working to bring legal limits in line with WHO advice. George Eustice (MP) has stated that
“the Government has introduced air quality measures in the landmark Environment Bill which was introduced to Parliament on 30 January. The Bill delivers key parts of the CAS and aims to deliver health benefits by tackling pollution, which is the greatest environmental risk to our health. It establishes a legally binding duty to set a target for fine particulate matter (PM2.5 refers to tiny particles or droplets in the air that are two and one half microns or less in width), in addition to a framework for setting legally binding environmental targets, including a long-term target on air quality. We are committed to setting an ambitious target for reducing PM2.5 concentrations, with a primary focus on reducing the public health impacts this pollutant causes. In July 2019, we published a report assessing the progress that will be made towards WHO PM2.5 air quality guidelines with actions outlined in the CAS by 2030. This report showed that significant progress would be made towards achieving WHO guideline levels through the actions outlined in the Strategy, but that additional action would be needed to reach WHO Guideline levels in specific locations (i.e. central London).” George Eustice MP.
As such, the government is working on legislation that will make the current levels of PM2.5 (as modelled by BHF) in the area illegal. As the report is modelling what air pollution looks like up to 2036, it needs to also take consideration of where the law is going, but it doesn’t. WBC will find itself in a position where it will have more AQMA’s and should be taking measures now to address this.
The report states that “the Council currently has three declared AQMA’s at Twyford Crossroads, Wokingham Town Centre and the M4, all declared for exceedances of the NO2 annual mean. The Site is located approximately 600 m southwest of the Wokingham Town Centre AQMA.” It then goes on to say that “NO2 concentrations increased from 2015 to 2016 where they peaked at 1.3 µg/m3 above the AQO. Concentrations then decreased in 2017 and 2018 and are currently within the mean annual air quality objectives for NO2.” What it fails to pick up on is that the decrease in pollution during the 2017/18 period was when the town centre regeneration works were taking place and often the roads were shut with reduced traffic. Of course pollution levels went down – they were not typical years.
This site being just 600 metres south of a current AQMA (which is an AQMA because it breaches legal limits of pollution), and will be a part of the diversion of traffic away from this AQMA is just shifting the problem. This will reduce pollution levels along Peach Street and move them to this location.
Given the importance of this proposed scheme, I’m amazed at the mistakes that have been submitted which makes me question the attention to detail that is compulsory to something like this. On the road marking plan document for example, part of the legend on the side is missing so it’s hard to understand the full plan. On the visibility analysis for pedestrians using crossing, it states makes reference to the Finchampstead Road South Toucan Crossing. Please remember, there is no toucan crossing in this location (see above). This does not fill me with confidence.
In the swept path analysis for an articulated vehicle, the Finchampstead Road North section has been omitted. I’m not sure if this a mistake or are articulated vehicles not allowed to use this section of road? If articulated vehicles are not allowed to use this section of road, where will the signs be placed that prohibit them using it?
As such, I do not believe that this proposal meets CP1, CP2, CP3, CP6 and CP21 and goes against the Council’s own requirements set out in the Core Strategy. There has been an opportunity missed to design something that is sustainable and in line with our climate change goals. I would strongly urge WBC to take this back to the drawing board and in the process, take greater consideration as to the impact of those living in the vicinity of the proposed junction.
All in all, I am objecting to this design and believe it needs a total rethink.
 The public consultation went live in the week of Christmas.