East Sussex County Council (ESCC)

 

(Draft) Response to the Transport for the South East (TfSE) Strategic Investment Plan (SIP)

 

12 September 2022

 

Contact Officer: Jon Wheeler, Team Manager – Infrastructure Planning & Place

(jon.wheeler@eastsussex.gov.uk)

 

The following response to these consultation questions will be presented to ESCC Cabinet on 29 September 2022. Therefore, subject to the outcome to Cabinet approval of our draft response, we may be required to provide further updates to our responses below.

___________________________________________________________________________

 

Consultation Questions

 

Section 2: Investment Priorities

 

a)    Which of the above investment priorities do you feel are important for the SIP to deliver?  (Tick all that apply)

·         Decarbonisation & Environment Checkmark with solid fill

·         Adapting to a New Normal Checkmark with solid fill

·         Levelling Up Left Behind Communities Checkmark with solid fill

·         Regeneration and Growth Checkmark with solid fill

·         World Class Urban Transit System Checkmark with solid fill

·         East – West Connectivity Checkmark with solid fill

·         Resilient Radial Corridor Checkmark with solid fill

·         Global Gateways and Freight Checkmark with solid fill

 

b)    Do you have any further comments on the SIP’s investment priorities?

 

We agree with the inclusion of the eight investment priorities. The initial four high level ‘policy-based investment priorities’ are critical for the region and also East Sussex. We recognise that these provide the ‘golden thread’ between national, regional, and local policies and priorities and which are associated with national funding streams. We will look to incorporate these as part of the imminent update to their Local Transport Plan (LTP).

 

We also recognise that these investment priorities will support delivery which is aligned with a move towards an approach for ‘planning for people and places’ which underpins both the TfSE Transport Strategy, the SIP and future iterations of LTP’s within the region. In terms of their importance, we recognise that there will be a need for greater urgency and emphasis on these four investment priorities from the outset to support the overall delivery of the SIP.

Regarding the more ‘transport related investment priorities’ we recognise that these are also important as they will support more outcome-based strategic investment for transport. We agree that they will significantly support the integration between transport and land use planning across the County, providing both strategic and more localised multi modal benefits particularly within our key growth areas where considerable housing and employment growth is coming forward.

 

 

 

Section 3: Packages of Interventions

 

For the purposes of data gathering and analysis, the TfSE region has been split into four geographies. Which of the following geographic areas are you most interested in? Please be aware that some local authority areas appear in more than one of the geographies and you may need to select more than one of the geographies if this is the case for your specific area of interest. Choose all that apply.

 

·         Solent and Sussex Coast (Hampshire, Southampton, Portsmouth, Littlehampton, Worthing, Brighton, Isle of Wight) Checkmark with solid fill

·         London – Sussex Coast (Chichester to Eastbourne, Surrey, West Sussex and East Sussex excluding the Hasting Area)  Checkmark with solid fill

·         Wessex Thames (Berkshire, Hampshire and Surrey)

·         Kent, Medway and East Sussex (Kent, Medway, Hastings and Rother areas of East Sussex) Checkmark with solid fill

 

 

Solent and Sussex Coast

 

a)    To what extent do you agree that the packages of interventions for the Solent and Sussex Coast area will deliver on the priorities of the SIP?

 

·         Definitely agree Checkmark with solid fill

·         Somewhat agree

·         Neither agree nor disagree

·         Somewhat disagree

·         Definitely disagree

·         I’m not sure

 

b)   Please select all of the packages for the Solent & Sussex Coast area that you feel are important in achieving the priorities of the SIP. Tick all that apply.

 

·         South Hampshire Rail (Core)

·         South Hampshire Rail (Enhanced)

·         South Hampshire Mass Transit

·         Isle of Wight (two Packages)

·         Sussex Coast Rail Checkmark with solid fill

·         Sussex Coast Mass Transit Checkmark with solid fill

·         Sussex Coast Active Travel Checkmark with solid fill

·         Solent and Sussex Coast Highways Checkmark with solid fill

 

c)    Do you have any further comments on the Packages of Interventions for the Solent and Sussex Coast area?

 

We are fully supportive of the Solent and Sussex Coast Package as this will strengthen east-west connectivity and resilience of the strategic and local highway network from Southampton across to Eastbourne.

 

The inclusion of the A27 Lewes – Polegate is critical. We continue to lobby for a more comprehensive solution to come forward for this part of the strategic road network between the two towns which would support the levelling up of our coastal communities compared to our neighbours and enabling the unlocking of opportunities for sustainable transport and reducing severance for communities along the existing A27. Equally we are supportive of improvements identified for the A259 South Coast Road Corridor – Eastbourne – Brighton, which requires a multi modal approach. This will build upon the current business case being developed for the corridor for Major Route Network funding from DfT to kickstart this approach.

 

We welcome the evidence at this stage to extend Sussex Coast Mass transit into East Sussex alongside Local Cycling & Walking Infrastructure (LCWIP) active travel measures. These measures will be a critical element of supporting the housing and employment growth coming forward in areas such as Eastbourne and South Wealden and provide a sensible and attractive approach towards supporting travel behaviour change towards public transport and active travel.

 

This will also align with the investment plans in bus priority and bus services coming forward as part of the ESCC Bus Service Improvement Plan (BSIP), which successfully secured over £41m of funding alongside a pipeline of schemes coming forward from the East Sussex LCWIP, which was approved by the County Council in September 2021.

 

We strongly support improvements to the urban public realm which will remove barriers to active travel, increase social inclusion, accessibility and health and wellbeing benefits. To that end, it is suggested the reference to Sussex Coast active travel enhancements (H1) is widened to include ‘Placemaking’ as well.

 

London – Sussex Coast

 

a)    To what extent do you agree that the packages of interventions for the London – Sussex Coast area will deliver on the priorities of the SIP?

 

·         Definitely agree Checkmark with solid fill

·         Somewhat agree

·         Neither agree nor disagree

·         Somewhat disagree

·         Definitely disagree

·         I’m not sure

 

b)   Please select all the packages for the London - Sussex Coast area that you feel are important in achieving the priorities of the SIP. Tick all that apply

 

·         London - Sussex Coast Rail (2 Packages) Checkmark with solid fill

·         London - Sussex Coast Mass Transit Checkmark with solid fill

·         London - Sussex Coast Active Travel Checkmark with solid fill

·         London - Sussex Coast Highways Checkmark with solid fill

 

c)    Do you have any further comments on the Packages of Interventions for the London - Sussex Coast area?

 

We support the comprehensive London - Sussex Coast package. This provides multi modal improvements across our networks within this area of the county, supporting both greater connectivity, particularly inter urban, and crucially resilience.

 

We strongly support the improvements to the rail network both in and outside the county – such as improvements at East Croydon - which will benefit passengers and freight travelling within, and to/from East Sussex. We also welcome the inclusion of the Lewes – Uckfield reinstatement in the draft SIP, which would significantly increase resilience and provide an appropriate alternative option to the Brighton mainline, as well as the electrification of the Hurst Green – Uckfield section of the line. We also support the proposal for a potential strategic transport hub near Eastbourne, which opens up opportunities for intercepting journeys into Eastbourne and its hinterland, which otherwise would be undertaken by car and moving them into either bus or rail.

 

Similar to the Sussex and Solent Coast package, we welcome the evidence to include both highway improvements, such as the A22 corridor improvements in South Wealden and from Hailsham to Uckfield, and mass transit schemes on key corridors of movement in the county. This will support housing and employment growth coming forward within these areas alongside improving access and safety for more rural settlements. This aligns with the bus infrastructure and service improvements coming forward as part of our BSIP.

 

We recognise the importance of improving the strategic cycleways within these areas of the county, which includes the ‘Avenue Verte’ and existing routes such as the Forest Way and Cuckoo Trail. This closely aligns with our LCWIP and the partnership with Sustrans to support improvements to the National Cycle Network which will be important to delivering this. This would provide direct safer cycling options for local journeys but also support a better-quality leisure cycling network within the region providing benefits to the local economy. 

 

We also support improvements to the urban public realm and placemaking in the likes of Eastbourne and Newhaven which will remove barriers to active travel, increase social inclusion, accessibility reducing health inequalities and providing health and wellbeing benefits. This would build on recent and planned investment in placemaking in Eastbourne, Hailsham and Newhaven town centres through transport or economic regeneration projects. To that end, it is suggested the reference to Eastbourne/Hailsham Local Cycleways (M3) and Lewes/Newhaven Local Cycleways (M6) are widened to include ‘Active Travel and Placemaking’ as well.

 

 

Kent, Medway and East Sussex

 

a)    To what extent do you agree that the packages of interventions for the Kent, Medway and East Sussex area will deliver on the priorities of the SIP?

 

·         Definitely agree Checkmark with solid fill

·         Somewhat agree

·         Neither agree nor disagree

·         Somewhat disagree

·         Definitely disagree

·         I’m not sure

 

b)   Please select all of the packages for the Kent, Medway and East Sussex area that you feel are important in achieving the priorities of the SIP. Tick all that apply.

 

·         Kent, Medway, and East Sussex Classic Rail Checkmark with solid fill

·         Kent, Medway, and East Sussex High Speed Rail (two Packages) Checkmark with solid fill

·         Kent, Medway, and East Sussex Mass Transit Checkmark with solid fill

·         Kent, Medway, and East Sussex Active Travel Checkmark with solid fill

·         Lower Thames Crossing

·         Kent, Medway, and East Sussex Highways Checkmark with solid fill 

 

 

c)    Do you have any further comments on the Packages of Interventions for the Kent, Medway and East Sussex area?

 

We are supportive of the Kent, Medway, and East Sussex area package as it sets out a multi modal approach which supports regeneration and growth and levelling up within this area of the county.

 

The inclusion of the High Speed 1 ‘Marshlink’ Hastings, Bexhill & Eastbourne upgrade will provide considerable economic benefits to this area of the county, levelling up these coastal communities compared to our neighbouring authorities, with a significant reduction in journey times between Bexhill / Hastings and London which will increase the attractiveness of this part of the county to both live, work and visit. We also support the inclusion of considering mass transit options for Bexhill and Hastings to encourage greater public transport usage in and between the two towns.

 

From a safety perspective and to enable localised active travel measures to be brought forward we welcome the inclusion of the highway’s element of the package, particularly the A21 safety improvements, the dualling of between Kippings Cross and Lamberhurst and the Flimwell and Hurst Green bypasses, which will remove strategic traffic away from local services, including schools, and reduce community severance.

 

We recognise the importance of improving the strategic cycleways alongside local and inter urban cycleways to provide a cohesive and accessible network within this area of the county. Therefore, we are supportive of this element of the package as it is in alignment with the East Sussex LCWIP and the partnership with Sustrans to support improvements to the National Cycle Network. 

 

We also support improvements to the urban public realm and placemaking in the likes of Hastings and Bexhill which will remove barriers to active travel, increase social inclusion, accessibility reducing health inequalities and providing health and wellbeing benefits.  Schemes to reduce traffic on the A259 through Bexhill and Hastings enable greater placemaking opportunities to come forward in these two settlements.

 

 

Global Policy Package of Interventions

 

a)    Which of the above Global Policy Interventions do you feel are important for the SIP to support? (Tick all that apply)

 

·         Decarbonisation Checkmark with solid fill

·         Public Transport Fares Checkmark with solid fill

·         New Mobility Checkmark with solid fill

·         Road User Charging Checkmark with solid fill

·         Virtual Access Checkmark with solid fill

·         Integration Checkmark with solid fill

 

b)    Do you have any further comments on the SIP's Global Policy Interventions?

 

We agree with the inclusion of the Global Policy Interventions as they cut across the eight key investment priorities, enabling change, adding greater value to the delivery of the priorities, and potentially supporting a faster pace of delivery. We appreciate that the level of impact of these may vary across the south east, depending upon whether they are delivered individually or in combination, or they may be required at different times throughout the plan period. Therefore, they all possess a level of importance to the overall delivery of the SIP.

 

We particularly welcome the benefits that these interventions will provide in reducing carbon emissions, but note that many of these interventions will require, particularly local authorities, to adopt a policy of travel demand management. They may also require innovative funding solutions and certainly ongoing revenue funding to incentivise travel behaviour change. Therefore, it is suggested that this is identified more clearly in the SIP.

 

 

Section 4: Benefits and Costs

 

a)    Do you think that the SIP captures the benefits and costs of the proposed packages of interventions adequately? Choose any one option.

 

·         Yes Checkmark with solid fill

·         No

 

b)   Please explain your answer to the above question here.

 

We agree that the SIP demonstrates that robust assessments have been undertaken to capture an appropriate level of benefits and costs, when considering the current stage of design of the packages of interventions. Notably the assessments to determine the costs and benefits have been developed through the utilisation of a transport and land use model which has specifically been developed for TfSE’s Strategy and SIP.

 

This model does appear to be both comprehensive and robust. However, it would be helpful to understand whether the impact of the Covid 19 pandemic has been factored into the reports including changes to travel patterns, volumes of movement, and mode share. If not, we would suggest that the SIP considers including a statement that requires the respective scheme promoters - local authorities, key strategic partners such as Network Rail and National Highways, or other partners such as Sustrans and potentially TfSE itself -to consider this as part of any further modelling or assessments as schemes come forward and developed in further detail.

 

It is also noted that the costs of interventions have been estimated using historic project data/industry standard data and adjustments to input costs. In view of the current economic conditions and the impact that this is having on materials, scheme delivery costs, labour costs and availability and the ongoing maintenance of schemes, it is suggested that the SIP should include a much clearer caveat that partners and stakeholders should consider these estimated costs with caution and that further work would be required to refine these cost estimates (up or down) as schemes come forward and are developed in more detail.

 

 

Section 5: Delivery of the SIP

 

a)    To what extent do you agree that, as a whole, the packages of interventions will deliver on the priorities of the SIP?

 

·         Definitely agree Checkmark with solid fill

·         Somewhat agree

·         Neither agree nor disagree

·         Somewhat disagree

·         Definitely disagree

·         I’m not sure

 

 

Section 6: Integrated Sustainability Appraisal and Conclusion

 

a)    Do you have any comments on the Integrated Sustainability Appraisal?

 

The ISA combines several assessment processes including Strategic Environmental Assessment, Health Impact Assessment, and the Habitats Regulation Assessment. Taking into consideration the stage of the interventions identified in the SIP, we would agree that the level of assessment undertaken is appropriate.

 

The integrated Sustainability Appraisal is comprehensive and importantly it demonstrates that it was initiated at an early stage of the development of the SIP during the evidence base review to enable areas of concern to be identified early in the ISA process.  

 

It clearly demonstrates that an appropriate methodology has been utilised where relevant local environmental policy was identified for each Area Study alongside relevant social, economic and transport data. We agree how this information has been used as part of a Multi-Criteria Assessment Framework (MCAF) to determine how well national and regional sustainability policies aligned with each of the interventions, and how this has supported further appraisal to inform mitigation.

 

We welcome the recognition, alongside the mitigation of the mechanisms required, for undertaking further assessments and appraisals as individual or packages of schemes come forward. East Sussex is covered by landscape and environmental designations, of both national and international significance, and we recognise the necessity of undertaking further assessments to either remove or reduce impacts to these environments and on our population’s health as and when transport interventions identified in the SIP are developed in the county. It is acknowledged that as a high-level plan the overall SIP will have generally positive impacts on health and wellbeing.

 

b)   Overall, to what extent do you agree that the SIP makes the best case possible for investing in transport infrastructure in the South East?

 

·         Definitely agree Checkmark with solid fill

·         Somewhat agree

·         Neither agree nor disagree

·         Somewhat disagree

·         Definitely disagree

·         I’m not sure

 

Additional comments

 

Equalities and Inclusion

We request greater reference to equalities and inclusion for people with protected characteristics during the development and delivery of infrastructure measures and interventions. It is recommended that this is referred to as early as possible within the document, but certainly in relation to the investment packages.

 

Travel Behaviour Change

The SIP does mention the ongoing revenue funding which will be required to incentivise and enable travel behaviour change specifically within the Global Policy Package of Interventions section. However, whilst we realise that this is a strategic document with travel behaviour change being critical to the success of several of the interventions, it is recommended that the need for travel behaviour change is mentioned earlier in the document within the introductory section.

 

Consultation

Just a brief comment in regard to consultation and the opportunities to consult with young people, particularly in regard to interventions within the Global Policy Package of Interventions, focussed on smarter mobility and the influence of this on future travel and transport.