Object

Representation ID: 66334

Received: 23/06/2014

Respondent: Mr Dennis Michael Crips

Legally compliant? No

Sound? No

Duty to co-operate? No

Policies TR2 and TR3 are inadequate due to the failings of the STAs. The STAs are based on a standard modelling tool and refer to peak times only. They do not assess impacts for the majority of the time. Taken together with false mitigation, this has led to erroneous conclusions. The needs of pedestrians have not been taken in to account and the mitigation is focused on reduced journey times for drivers of vehicles at peak hours only when the measures will be 24/7. This will means traffic is stopped even when it doesn't need to be, causing unnecessary delay and pollution.
There are also errors of fact such as with tables 32-35 of the STA phase 3. This undermines confidence in the documents submitted as evidence and validity of the data.