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LETTER to Highways Agency from The Blackwater Valley Action Group
June 9th 2005
Dear Mr Shuker I am writing on behalf of the Blackwater Valley Action Group about the proposal for a new section of the A120 from Braintree to Marks Tey. The Group was formed by a group of concerned residents of Coggeshall, Kelvedon and Feering to promote the River Blackwater Valley and protect it from the proposed ‘Southern Route.’ The Group organised a Public Meeting in Coggeshall in April attended by nearly 200 people who at the end of the evening showed themselves to be overwhelmingly opposed to the “Southern Route”. On the May Bank Holiday the Group arranged a Walk through that part of the Blackwater Valley which would be most affected by the proposed route. On that occasion there was an attendance of over 300 including the candidates for the Parliamentary seat and the Local Authority elections and once again there was clear opposition to your proposition.At the start of the consultation period quite a few people favoured your proposed route for the simple reason that other routes that you showed might be worse for them. It has become clear however, that since February positive support for the route is minimal to non-existent among residents of this part of Essex . It is notable that in the last month alone no one voted in favour of the proposed route at public meetings arranged by the Kelvedon and Stisted Parish Councils and that Coggeshall Parish Council have voted to have an alternative link to the A12 investigated. Summary of the Blackwater Valley Action Groups views. The Group recognises that the extension to the A120 is essential but is opposed to the proposed Southern Route on the following grounds: 1. Environmental The permanent detrimental impact on the Blackwater Valley and its flora and fauna - an exceptional landscape of high quality and of historic importance. In particular the length and height of the required crossing of the River Blackwater. 2. Traffic The location of the link with the A12 which would attract considerable increased traffic volumes through the villages of Coggeshall, Feering and Kelvedon onto low grade local roads which have dangerous bends and junctions. 3. Flood Risk The villages of Coggeshall, Feering and Kelvedon suffered major flooding in October 2001. The crossing of the flood plain and the run-off from the carriageway and other hard surfaces will impact on water levels. The design to meet the 1 in 100 year (or 1in 120 year) incidence at current day predictions will almost certainly prove inadequate over the lifespan of the new road and would have not have proved adequate to deal with the local floods in 1987 and 2001. The Group is also opposed to the nature of the consultation exercise. It considers that to be restricted to one route on which to make comment does not constitute meaningful consultation. It is no different to having only one candidate to vote ‘for’ or ‘against’ at an election. The Group believes that there are other routes and in particular one which would link to the A12 between Witham and the Kelvedon South junction should be investigated. This would not only be the shortest route but would have less environmental impact and would assist with the resolution of traffic serving Tiptree and industrial areas of Witham.
The Group therefore urges the Highways Agency to conduct further studies and to offer other routes for public consultation. The Group offers further evidence and comment in the following paragraphs in support of the Summary set out above. Environmental
The Blackwater Valley between Kelvedon and Coggeshall, provides an extremely valuable and precious wildlife corridor. The river and its margins support a wealth of biodiversity because they are tranquil and to a great extent undisturbed by human activity. The valley consists of a wide variety of habitats; ancient water meadows, still backwaters provided by the monastic fishponds, dense thickets of mature hedgerows, small woodlands, large private gardens with many different shrubs and trees, willow plantations, and lush river edges which are a haven for water creatures. A wide variety of birds and mammals depend on this habitat and the extent of it is a rare commodity in this over-developed part of the country. The peacefulness and closeness to nature afforded by the valley which is crossed by many footpaths, is also very valuable to the human population. It is still an oasis of green calm but it is also very fragile. The effect of a major trunkroad spanning this valley, would be devastating and irreversible. No amount of damage limitation by the Highway Authorities could lessen its destructive impact on the environment. The noise from the heavy traffic using the road would be hugely intrusive and nothing could mitigate against that form of inescapable pollution which would sweep down and across the valley. This indisputable fact was confirmed by the Project Director, James Dessain, the Project Manager Graham Martin and by Richard Gwilliam, the Environmental advisor who have both walked along the Blackwater. The light pollution from juggernauts as well as other traffic would also intrude into the darkness which is so important to wildlife particularly to those creatures which hunt at night. The visual impact of the road bridge would also be extremely disturbing and would alter forever the character of this beautiful landscape. It must be concluded that this route would have the most serious environmental impact of any others explored by the consultants on behalf of the Highways Agency and this must be a major factor in the decision-making process. This landscape and its wildlife are at risk and their protection should be given the highest priority.
The Group is consulting amongst others Essex Wildlife Trust who will be providing a detailed report in the autumn of this year. John Hunter an expert on Historic Landscapes considers the Blackwater Valley to be an exceptional and unique landscape of very high quality due to it being the world centre for the growing of the cricket bat willow. It also has adjacent to the proposed crossing the finest and most complete monastic landscape in Essex and possibly East Anglia . We challenge the statements made at the consultations about your proposal not directly affecting “areas of environmental interest” and the land taken being of “low ecological value.” To the east end of the route is the Feering Conservation Area. There is an overwhelming concern that the route could not fail to have an impact on this conservation area and indeed on the local community thereabouts. Visual intrusion, noise, air pollution and severance are all major issues. These issues are recognised in your consultants’ own Technical Assessment but seem to have carried little weight in your deliberations. Traffic Problems and the integration of the A120 and the A12The area of concern to us is a triangle of rural Essex bordered by the A12 (and parallel London to Ipswich railway line) and the current A120. The A12 is by far the most important local road, with an estimated 70,000 vehicles a day on the 2-lane dual carriageway between Hatfield Peverel and Marks Tey. There are regular serious congestion issues in the Feering, Kelvedon and Witham areas, which spill over into the local villages when there are accidents or breakdowns. The A12 is in serious need of upgrading to 3-lanes in this part of Essex and we hope that the Highways Agency will be able to co-ordinate its plans for this with its proposals for the new A120. There is legitimate concern that the route would create or aggravate local traffic problems. There are also concerns that the route could increase local flooding or lead to an unacceptably large bridge over the Blackwater between Coggeshall and Kelvedon/Feering. The proposed route could even lead to the eventual obliteration of a beautiful, peaceful and heritage-rich part of rural Essex . We recognise that the current A120 also needs upgrading, but we remain unconvinced that your proposed route – a dual-carriageway with no junctions between Braintree and the A12 north of Feering – is a credible solution. The route would do much less to relieve existing A120 traffic than some other routes. The proposed route would create a ‘rat-run’ of traffic from the Coggeshall area aiming to join the new road north of Feering. Also long-running problems of Tiptree traffic accessing the A12 via Kelvedon or Feering would be perpetuated and made worse by the proposed route. Local residents are also fearful of the probable weakening of planning restrictions that could follow the building of the road that you have proposed. They have real concerns that the valley would be in danger of wholesale development. The real fear they have is that once the area has been impacted by the road then planning restrictions would be weakened resulting in comprehensive urbanisation of the valley. Moreover, the justifications put forward by your consultants for this road are unconvincing – if not misleading. To this day your consultants seem more interested in “selling” their route than understanding local concerns and suggestions. Indeed this attitude - starting at the Coggeshall public consultation - was one of the triggers for the formation of our Action Group. Flooding A further cause of anxiety is flood risk in villages that were very seriously flooded as recently as 2001. This fear is fuelled by a concern that your consultants may have under-estimated this in their technical assessment. As for the bridging of the Blackwater we note that in their Technical Assessment the consultants assume that a bridge over the Blackwater would have a 100 metre span. We believe that the public may have been misled in the public consultation by suggestions that the bridge would be much smaller. Our researches suggest that with the issues of flooding, floodplain and valley topography the bridge may need to have a span in the region of 400 metres. Such a structure would be significantly more obtrusive than the presentation or documentation suggests and the resulting visual and noise pollution from the bridge would be terrible. Economic arguments Regardless of the environmental, traffic or social implications of your proposed route, we note that you and your consultants have sought to justify the decision mainly on economic grounds. We have sought to understand how your consultants could have concluded that the proposed route is “twice as good” as any other routes studied. There were considerable delays from your staff in providing the information required and this served only to heighten the belief that the analysis may be flawed. The most serious flaw to this economic justification for the route is the decision not to investigate options between Witham and Kelvedon, even though Essex County Council had identified such a route (Option F in their Stage One 2002 Study) as being the least environmentally damaging and under certain scenarios the cheapest. (The Technical Assessment disingenuously states that Essex CC was a party to this decision, even though we understand that the Essex representative present was on secondment from Essex CC and was under Highways Agency direction and confidentiality.) The economic justification of your proposed route is based on criteria which are open to challenge. Even more seriously, it can be concluded that the same economic criteria used by your consultants to justify the Blackwater Valley route would probably show an even greater 'cost/benefit' and 'net present value' for a route joining the A12 between Witham and Kelvedon. (We refer to the letter to you on 17 May 2005 by Mr K R Winckle for a detailed analysis of the economic justification of your proposed route. This letter is attached as Appendix A, with Mr Winckle’s permission.) So, one is entitled to ask, what is the overriding reason for not even considering a route originally put forward by Essex CC and which that body’s own consultants had rated so highly? The Technical Assessment on page 45 states that “a north-south route such as Option F in the Stage 1 Scheme Assessment would be inappropriate as it would not meet the east-west route scheme objective”. This is incredible, for a number of reasons. First, such a route would be north-west/south-east not north/south. Secondly you have indicated that one of the strategic drivers for the new A120 being of such a high standard is that it would be part of the Trans European Network (Dublin to Brussels): the main East Anglian part of this would be the A14, which you are also proposing to upgrade, but this would be supplemented by a route involving bringing traffic some 30 miles due south along the M11 before turning left at Stansted along the A120. In the overall context of the road a north-west/south-east section between Braintree and Witham/Kelvedon to join a 3-lane A12 would not be a disincentive for the long-distance traffic which we understand to be your main concern. Furthermore it could also help to improve the traffic in the Witham area. If on the other hand, the East-West route is deemed so strategically important, we would suggest that is for your Agency to present other proposals which would not affect the Blackwater Valley or any other equally environmentally sensitive areas. The drawing of a convenient line across a map joining two points reveals that the affects of the proposed route have not been thoroughly considered and justified.
Conclusion
The group has enjoyed considerable support from local residents many of whom do not live near the proposed Blackwater Valley crossing but are anxious about the issues of traffic and flooding and who above all would not wish to see this beautiful part of Essex devastated by a vast expanse of concrete. We have also had enormous encouragement from politicians of all persuasions who believe that the process of “consultation” adopted on this occasion is unworthy of the name and who wish to see other options being offered. In view of the extent of the public rejection of your proposed route, and the questionable economic justification of it prepared by your consultants, we would ask you to announce as soon as possible that you are not proceeding with this route. Instead we would ask that you offer proposals for consultation that better meet the needs and concerns of the residents of the area through which the new A120 would pass. The Blackwater Valley Action Group would be pleased to discuss any of these issues further with you. Yours sincerely Alan Willis Chairman, Blackwater Valley Action Group Enc. Appendix A: letter from Mr K R Winckle to the Highways Agency |
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