The Environmental Case

In common with most UK towns and cities, Bath suffers from traffic congestion in the morning and evening peak hours. In contrast to popular perceptions, however, volumes are not steadily increasing and this was highlighted in the 2014 B&NES Council ‘Getting Around Bath’ transport strategy and demonstrated by DfT data from the two principal eastern arteries within Bath – A4 London Road and the A36.

fig3Fig. 3 data illustrates that traffic volumes (including HGVs) in the vicinity of Bath have been declining and that 95% of total traffic is cars/vans and just 5% is HGVs. This is also comparable with data from the 2004 Government commissioned Bristol/Bath to South Coast Study (BB2SCS). This study also indicates the bulk of traffic along London Road comprises non-through movements at 88%. Car/van and HGV through-movements contribute 8% and 4% respectively, with only part (75%) originating from the Warminster Road. Data therefore illustrates two important points -(i). The vast majority of Bath traffic is cars/vans making trips over very short distances, and is not dominated by through-traffic. Any Local car/van traffic removed from the London Road, as a result of a link road, would have to access/egress Bath via other routes. Any released capacity would soon be taken up by suppressed demand, so while London Road might initially see a small benefit the Bath area, as a whole, would see no improvement – as demonstrated by traffic modelling in the 2004 Bristol, Bathto South Coast Study (BB2SCS).(ii). Through HGV movements are less than 4% of total traffic flow along London Road.

Potential impacts upon WHS and UNESCO World Heritage City designations and wider implications are hinted at, but nowhere resolved, e.g. in B&NES Council policy documents: WHS Management Plan, Consultation Draft, May 2016, and A Green Infrastructure Strategy for Bath & North East Somerset, March 2013.

Environmental Case

These policy documents and their omitting of reference to it as ‘infrastructure development’ suggest some reluctance to tackle underlying issues first raised by proposals in the mid 1980’s, while an A36/46 link road has again been put forward as if a new proposal for consideration in Council Transport Strategy, as ‘partial solution’ to traffic congestion and pollution.

A typical contradiction is seen in this extract…
“ Transport and moving around the WHS is a major issue. Being contained within a hollow in the hills with protected landscape beyond, both topography and planning restrictions rule out a ring road or by-pass. North-south (A36/A46) and east-west (A4) principal road routes pass through the city. Roads can therefore be congested, with resulting air pollution and other detrimental impact on residents and businesses. Car ownership levels are also high and parking of private vehicles is problematic.” Whilst a traffic-inducing ring road or by-pass may be considered environmentally inappropriate a link road, essentially serving the same purpose, may not.

Valuing People, Place and Nature

The responsibility to protect the WHS landscape setting is also set out in a number of material international, national and local documents, e.g. 2008 City of Bath UNESCO report; 2009 Government Circular on WHS protection; 2009 B&NES Public Realm and Movement Strategy; 2010 WHS Management Plan; 2013 WHS Setting Supplementary Planning Document.

DfT Data for count point 57772, A4 into Bath, Past Cleveland Place junction (2000-2014)

As an illustration of modal share, at the meeting point of A46 and A36 traffic in Bath, disparities are shown between link road proposals as part of B&NES Council Transport Strategy and actual trends.
Recent increases in LGV traffic show definite trends that would not be addressed by building a link road.
The low number of HGVs is compared to other route users as:
A46 (Charmy Down) – 26% increase in cars , 63% increase in LGVs, 18% reduction in HGVs
A4 (East Bath/Link Route) – 15% increase in cars, 74% increase in LGVs, 5% reduction in HGVs
A4 London Road – 31% reduction in cars and HGVs, 8% increase in LGVs
Walcot– 12% reduction in cars, 45% reduction in HGVs, 17% increase in LGVs

fig7

A link road built in the vicinity would attract more traffic – to the extent that emission limits would be exceeded – in the absence of evidence of need or any understanding of who travels where and for what purpose, and in conflict with B&NES Council’s adopted environmental policy. For example, Bathampton is on the edge of an Air Quality Management Area (AQMA), with emissions just below EU limits and on a rising trajectory, while parts of London road already exceed them.

The data (Fig. 6) also leads to the conclusion that the vast majority of traffic in Bath is cars/vans undertaking trips over very short distances, i.e. is ‘local’ and not dominated by through-traffic, a fact recognised by B&NES Council in stating; “In the Bath urban area, Government figures suggest that fewer than 1 in 20 cars represent through traffic.” Causes of congestion, as suggested in the 2013 Gillham evidence, continue to be ignored.Limpley Stoke Valley

Whilst Local Authority environmental policies are clear it is inexplicable that A36/46 link road proposals and aspirations expressed by local MPs do not correspond to the available data, where it was misleadingly described by one MP as a ‘bypass’ in 2015 lobbying of the Chancellor of the Exchequer:

“The local Council has recently decided that this bypass is one it wishes to be built. Therefore, we hope that a thorough investigation of this project can be made. We both agree that a link road should be of such architectural merit as to enhance the beautiful landscape that is part of the wide Area of Outstanding Natural Beauty, improving rather than simply preserving this unique city.”

However, and without attributing credit to the misleading ‘Astroturfing Strategy’ of describing a ‘beautiful landscape enhancement’, the fundamental conflicts associated with new road engineering structures in environmentally sensitive areas, or assessments such as SACTRA 1994 and BB2SCS 2004, can neither be ignored nor denied.

e.g. The report of B&NES Planning, Transportation & Environment Committee 16th November, 2000, article 6.4:
“Turning to a somewhat controversial, but intuitively more effective option, there is much talk of re-visiting a version of the A46/A36 link that was rejected as part of the Batheaston Bypass scheme at the 1990 Public Inquiry. Such a scheme would undoubtedly be the only option that would allow through traffic movements to be removed from Bath with confidence. It should also be possible to relieve Bath of some of the traffic movements between A36 Warminster Road and Bristol which currently use A36 through Bath and A4 through Saltford, by transferring these movements via the link to A46/A420 and M4. However a link road carries with it the risk of generating some extra local movements, as would any such road scheme close to an urban area, and there would be an inevitable intrusion into the landscape.”
Despite the failure in this or any known recorded evidence to address the levels of though-traffic or actual traffic trends, as described by DfT data in Fig. 6, these and similar views continue to actively encourage discussion of linking the A36/46 routes around Bath and in denial of the compelling evidence and judgements made agains all previous and similar proposals. Those proposals are summarised in the following section.