Northern Gateway Area Action Plan

Our response to the Proposed Submission

1 October 2014

Scale of development

The proposal to increase the amount of housing by 150% will necessitate very careful consideration of the quality of the accommodation provided. The City Council adopted Core Strategy is rightly at pains to acknowledge the adverse environmental factors characteristic of the Northern Gateway site. Furthermore, the proposed increase in housing provision, over the Core Strategy allocation, is not the result of re-allocation of areas previously designated for other uses, hence the implication is that the increase will result from higher density and/or smaller unit sizes. The UK already has some of the lowest space standards in Europe for residential accommodation, and the Proposed Submission document fails to demonstrate adequately how or where decent-standard accommodation, either in terms of living space or environment, can be provided, with the proposed very large increase in housing allocation.

Core strategy policy CS6 lays down maxima of 55,000 m2 for Class B use and 200 dwellings. The AAP proposes increasing this to 90,000 m2 but this is only partially accounted for by the re-allocation of the provision in the Core Strategy for emergency services operations. The remainder is allegedly made up of post-2026 allocation in the Core Strategy, however, the Core Strategy defines policy to 2026 and we query the legality of the failure of the AAP to comply with the Core Strategy in regard to the scale of the development and the timetable therefore.

The proposal to bring forward all the ultimately-projected development of 90,000m2 B1 floor space imposes greater challenges in terms of mitigation of traffic generation than even those outlined in the adopted Core Strategy. We express below our serious concerns at the inadequacy of the analysis of the traffic implications of the development of this site. We believe that the enlargement (above the provisions of the Core Strategy allocations) of the major traffic-generating elements of the proposed development should not be considered until all the relevant issues have been fully examined and a comprehensive range of measures implemented to ameliorate all the already-unacceptable environmental conditions in the neighbourhood.

This development to which this Area Action Plan relates obviously constitutes a major development right against the boundaries of the City Council administration. At the current time the policies of the adjacent authority, Cherwell District Council, are in course of establishment, but it is clear common sense that development of the Northern Gateway must consider proposals for development not only within the boundaries of Oxford City Council, but anywhere adjacent where there may be interaction, interference or contributory consequential effects. The Proposed Submission documents provide no evidence of adequate consideration of this, or of the fulfilment of the statutory duty of all relevant Local Authorities to cooperate in the preparation of policy and the management of development. This is a serious shortcoming, rendering the AAP unsound in our view.

Traffic and Transport

The City Council Core Strategy confirms (paragraph 3.4.34): “The main constraint to development relates to access and traffic generation. The Northern Gateway area experiences significant peak-hour congestion and the County Council has developed proposals for highway improvements as part of the ‘Access to Oxford’ package. The highways and transport mitigation measures will need to be resolved before any development takes place.”

Thus, an over-riding consideration for the development of the Northern Gateway is the mitigation of the effects of traffic – not just the effects of new traffic generated by the development, but those of existing traffic, and of the predicted ‘background’ growth in traffic. These effects are:

congestion on all adjacent roads,
severe noise nuisance,
chronically poor air quality, and
severance of suburban residential communities.

The Proposed Submission AAP acknowledges this in para. 2.4. However, since off-site highways matters are not within the remit of Oxford City Council, nor within the scope of the Area Action Plan, the alleviation of these effects is very much dependent on collaboration with and availability of funding to Oxfordshire County Council. The County Council’s ‘Access to Oxford’ package of improvements to the highways network has, of course, been abandoned.

Paragraph 3.4.44 of the adopted Core Strategy states: “The Northern Gateway Steering Group will bring together a range of key stakeholders, including the Northern Gateway Consortium (landowners/developers), the City Council, Highways Agency and Local Highway Authority. This group will work with the local community to deliver the development of this site. The Northern Gateway Transport Strategy will be developed and delivered in partnership with the Highways Agency and the County Council to reduce the need to travel, promote sustainable travel choices and accessibility, and link with the wider ‘Access to Oxford’ proposals to mitigate the potential impacts of the new development.”. It is not clear if the Northern Gateway Steering Group is still in existence, but the AAP Proposed Submission document makes no reference to it, and provides no evidence of it ‘working with the local community’. No ‘Northern Gateway Transport Strategy’ has been presented, and the ‘wider ‘Access to Oxford’ proposals’ are no longer being progressed. The Proposed Submission is seriously deficient in not explaining whether or how these undertakings adopted by the City Council have been replaced by any acceptable alternative activities aimed at fulfilling the same objectives. In the absence of such acceptable alternatives, and absolute assurance that they will be implemented, the Area Action Plan is unsound.

Whilst the AAP may have the capacity, through application of development policies, to moderate the generation of ‘new’ traffic volumes, the acceptability of any development of the Northern Gateway site will be absolutely conditional upon the implementation of measures which are capable of reducing to acceptable levels all the adverse effects listed above of traffic of all types.

Given that traffic conditions and the effects thereof are already unacceptable, and that it is inevitable that any development will generate some more traffic (45% more by 2026 than that envisaged by the Core Strategy), it follows that before development of the Northern Gateway takes place it is essential to mitigate not just new traffic generation, but also traffic using adjacent highways but not associated with the Northern Gateway site.

The Core Strategy emphasises in paragraph 3.4.34 that traffic mitigation measures must precede development of the Northern Gateway. The statement in paragraph 2.10 of the Proposed Submission document that: “…improvements would be tied to phases of the development….” is thus inconsistent with adopted policy, and is unacceptable. This failure to conform to policy set out in the Core Strategy renders the AAP unsound.

Alleviation of the effects of traffic can only be achieved by either reducing the volume of traffic, or increasing road capacity. Increasing capacity can reduce congestion, and improved traffic flow may possibly reduce air pollution. But improved flow can increase noise and community severance as well as leading to increased traffic volumes, if a route becomes more attractive, leading to restoration of the congestion status quo. The Proposed Submission AAP ignores this potential effect.

A desirable vision for the Northern Gateway neighbourhood might be one in which through traffic avoids the urban development areas of north Oxford altogether, and commuters, whether to the Northern Gateway or elsewhere, have adopted public transport, cycling or walking as the preferred and predominant modes of travel.

Delivery of this vision would necessitate the provision of:

attractive alternative routes, clear of the Northern Gateway site, for through traffic,
more frequent, faster and more reliable bus (or other public transport) services,
really attractive, convenient, direct and safe routes for cyclists and pedestrians.

The Proposed Submission AAP document, with its suite of background papers, unfortunately offers no evidence of any commitment to delivery of this vision, or to the implementation of the necessary provisions listed above. Whilst there is a statutory duty to cooperate applicable to all relevant Local Authorities, there is no evidence provided that this duty has been fulfilled, either, for example, by confirmation by the highway authority that it is minded, and in a position to implement the comprehensive measures necessary to make the development proposed acceptable. We suggest that this failure to demonstrate that the duty to cooperate has been fulfilled, such that the conditions on development set out in the Core Strategy are certain of achievement, renders the AAP unsound.

The only measure suggested which might possibly divert a proportion of through traffic is the A40 – A44 ‘strategic link road’ west of the A34; some funding is apparently available for construction of this, but no data are presented on its likely effects on traffic flows and the AAP specifically contends that this strategic link is unnecessary, without setting out the criteria upon which this judgement is made.

This assertion can only be based on the findings of the Oxfordshire County Council North Oxford Transport Strategy (NOTS) report, that the capacity of the Wolvercote and Cutteslowe roundabouts is capable of being increased adequately to accommodate the predicted levels of traffic. The NOTS report gives no consideration to any of the other effects of increased volumes of traffic, except in regard to the capacity of the Wolvercote and Cutteslowe roundabouts.

The NOTS report predicts that by 2031 the total volume of traffic approaching the Northern Gateway site on all routes will have increased by about 60% compared with 2013 levels. About 43 % of the increase will be attributable to the Northern Gateway development itself, despite the constraints of Core Strategy policy CS 13, which asserts that: “Planning permission will only be granted for development that prioritises access by walking, cycling and public transport”.

Appendices C, D and E of the NOTS report contain a number of errors and omissions; nevertheless, they reveal that, apart from the general increase in traffic volumes around the site, there are particular cases which would be causes of especial concern.

The following table summarises some of the figures from the NOTS report:

NORTHERN GATEWAY

Traffic approaching site in a.m. peak hour

Figures from Appendices C-E of WYG’s Technical Summary Report June 2014

	2013	2031 without NG			2031 with NG
	pcu	pcu	change on 2013		pcu	change on 2013
A40 eastbound approaching Wolvercote rd-about	764	1093	329	43%	1015*	251	33%
A44 southbound from Peartree	1566	2041	475	30%	2834	1268	81%
A40 westbound on Sunderland Ave	1029	1365	336	33%	1562	533	52%
A4144 Woodstock Road approaching W’cte rd-about	589	753	164	28%	858	269	46%

* 131 pcu diverted via A40-A44 link within NG; further west it is 1109 (+345, or 45%)

Further examples of traffic volume increases which merit detailed consideration are:

inbound evening traffic on Woodstock Road – shown to increase by 60%. There is no discussion of the capacity of the road downstream of the roundabout to accommodate this increase, no consideration of the environmental and social consequences, and no recognition of the possibility that congestion downstream might influence traffic flow at the Wolvercote roundabout itself
westbound morning peak-hour traffic on Sunderland Avenue from Cutteslowe roundabout is shown to increase by 55%. The lack of consideration of consequences, as outlined above, is unacceptable.
eastbound evening peak-hour traffic on Elsfield Way increasing by 61%. The lack of consideration of consequences, such as congestion at Marston or Headington is unacceptable.
traffic on Banbury Road, morning and evening through the heart of Summertown increasing by around 35%. Again, the lack of consideration of the consequences of this increase on social or environmental conditions at this Local Centre is unacceptable.

The AAP proposals, and, specifically, the consideration given to transport and traffic issues are thus wholly inadequate in that the traffic analysis covers a much too restricted part of the highway network to enable proper consideration of the effects of the development proposals, and there is no consideration given at all to the environmental and social effects of the very large increases in traffic flows predicted. These deficiencies render the Area Action Plan unsound.

Despite the shortcomings in the data presented it is clear that the mitigation measures for which there can be any confidence of delivery will not prevent very significant harm to the conditions in neighbourhoods surrounding the Northern Gateway site. The fact that there is no evidence presented of any consideration of this harm is a serious deficiency in the AAP.

The only measures proposed for mitigation of adverse traffic effects and for which there is reasonable confidence of delivery are limited almost exclusively to improvements to Wolvercote and Cutteslowe roundabouts. These improvements are aimed chiefly at improving the capacity of the roundabouts to accommodate increased motor vehicle flows. These proposals are flawed in numerous respects, as we have pointed out in our response to the Oxfordshire County Council consultation (see attached Appendix 1), but perhaps most importantly they do nothing to improve the convenience or attractiveness of cycling and pedestrian access to the Northern Gateway site. Although safety may be improved by the installation of light-controlled carriageway crossings, the routes are convoluted and inconvenient. This contrasts with Core Strategy policy CS 13 requiring that all Northern Gateway development must prioritise access by walking, cycling and public transport, and is also inconsistent with the vision expressed (paragraph 3.4) in the Proposed Submission document that: Pedestrian routes linking open spaces and community facilities are safe and easy to use.”. The AAP document is thus inconsistent, as well as being at variance with the adopted policy CS13.

It is understood that preparation of a wider-area Oxford Transport Strategy is currently in progress. It may be that this will address some of the criticisms outlined above relating to documents available to this consultation. Meanwhile it is certainly premature to proceed with procedures for the adoption of the Northern Gateway AAP before this wider analysis of transport and traffic conditions is available, the conclusions and implications can be properly and fully considered, and the likely essential, comprehensive measures put in place to address them. Without assurance that such measures will be implemented, the AAP is unsound.

The AAP Proposed Submission document refers to other measures to mitigate the effects of heavy traffic flows on the A40 and A44 through the site, and to facilitate access to it by cyclists and pedestrians. We are certainly supportive of this intention. The references are to measures such as a 30mph speed limit and multiple light-controlled pedestrian crossings. However, no evidence is provided of the agreement to these measures by the County Council as Highway Authority, or certainty offered that they will materialise. In similar circumstances at Barton, less than two years ago and despite protracted negotiation, the County Council refused at a late stage to agree to even a 40mph speed limit, or to any dedicated at-grade cycle or pedestrian crossings. It is thus not possible to have any confidence that the similar proposals currently outlined have any prospect of being delivered. Without certainty of delivery of measures of this kind, the possibility of the achievement of acceptable access arrangements or environmental conditions at the Northern Gateway is too remote to be regarded as credible. Without genuine assurance that such measures will be implemented, the AAP is unsound.

In the course of this consultation it has been confirmed in the press that Government funding for some highways infrastructure improvements (other than to the Wolvercote and Cutteslowe roundabouts) in the Northern Gateway area has been refused. This makes the delivery of measures which might enable the achievement of acceptable conditions at the Northern Gateway even more remote, and increases uncertainty regarding the likelihood of implementation of any effective measures to mitigate the effects of traffic, without which the AAP is non-compliant with policies adopted under the Core Strategy, and hence unsound.

It is surprising, and negligent that the AAP Proposed Submission document makes no reference whatsoever to Core Strategy policies CS 13 and CS 14, particularly in view of the abandonment of measures such as the County Council’s ‘Access to Oxford’ proposals, referred to therein as being the mechanisms for delivery of the objectives of these policies.

We support the intentions expressing in policy NG4 but are concerned that the possible northern cycle route to Oxford Parkway is a) remote and b) uncertain to be provided. Alternative routes to the Water Eaton Parkway station from the northern end of the Northern Gateway should be much more fully explored. Reference is made to the new pedestrian bridge over the railway on existing footpath 229/10 made, but there is no evidence provided of the necessary cooperation by Oxfordshire County Council, Cherwell District Council or the landowners concerned that this provision will enable convenient access from the Northern Gateway site to the new station. We consider that this is another example of the suggestion of a facility to be provided, without any evidence that it is likely to materialise, or that the statutory cooperation necessary for it to do so has taken place. Failure to cooperate in this way would contribute to the unsoundness of the Area Action Plan.

Design and Environment

We support the development of a Design Code mentioning in NG7. We hope that the effect will be more ‘Science Park’ than ‘Business Park’. In particular that car and cycle parking and utilities are hidden from public view as on Magdalen Science Park.

We query why it is felt desirable to provide a way to avoid a Habitat Regulation Assessment in NG8. We note that Oxford City Council does not have an impeccable record on screening decisions cf Castle Mill EIA, and we suggest that this is reconsidered carefully.

In addition to district energy schemes suggested in policy NG9 we hope that developers will be encouraged to install photovoltaic panels mounted on acoustic barriers to provide some generation capacity. As a Gateway site we hope that higher standards should be set for energy efficiency of all development rather than just compliance with existing ones.

Conclusion

The key prerequisite to any development of the Northern Gateway site is the resolution of the problems of serious traffic congestion, noise, chronic air pollution and severance of and from neighbouring communities.

This issue was debated at length at the Public Examination of the Core Strategy in 2012 and is reflected in the text and policies of the adopted Core Strategy. The failure of the AAP Proposed Submission to conform to, or justify adequately departure from the terms of the adopted Core Strategy, in a number of respects, contributes to it being unsound, and, potentially, we suspect, of being illegal.

The assessment of likely volumes of traffic on roads associated with the development of this site indicates very large increases. The absence of any assessment of the consequences of the predicted increases, apart from the need for increased road capacity, contributes substantially to the Proposed Submission being unsound.

The measures which currently have reasonable certainty of being implemented, to ameliorate the effects of much increased volumes of traffic are much too limited in scope to give any confidence that the environmental and social conditions on the site and in the neighbourhoods adjacent are not likely to be significantly harmed. On the contrary, the evidence provided confirms that significant harm is likely to result from the development unless much more comprehensive traffic reduction measures can be guaranteed. Without such guarantees, the Area Action Plan is unsound.

The only measure by which the reasonably-certain proposals for dealing with the large volumes of traffic are likely to be successful is the possible reduction in traffic congestion at the Wolvercote and Cutteslowe roundabouts. Even the proposals for alteration of these roundabouts would still fail to provide attractive, direct and convenient access routes for pedestrians and cyclists – one of the stated objectives of the development.

Other measures which could reduce traffic volumes and thus mitigate the adverse conditions resulting from the large volumes of traffic on roads transecting the site have too little certainty of delivery to be credible in providing confidence that condition on the site, and in neighbouring communities, are likely to be acceptable.

The AAP fails to demonstrate that the essential cooperation between the highway and other local authorities has taken place in the preparation of the plan. Such necessary cooperation relates to the principle of development, the scale of the development, the resolution of issues associated with traffic, including congestion and air quality already occurring and likely to be exacerbated by the development, and to access provisions for the encouragement of active travel modes. The failure to demonstrate fulfilment of statutory obligations for cooperation constitutes unsoundness in the plan. This is especially relevant in the light of previous experience with the Public Examination of the Core Strategy and the Barton Area Action Plan.

For these reasons we would object to the adoption of the Northern Gateway Area Action Plan Proposed Submission.

APPENDIX 1 WOLVERCOTE AND CUTTESLOWE ROUNDABOUT CONSULTATION

General points

The proposals shown suffer a number of fundamental flaws in their presentation. Firstly, there no evidence provided of any strategic thinking behind the design proposals. Any schemes in the vicinity of the Ring Road should be developed only after opportunities have been fully explored for reducing the volume of traffic approaching the city in the first place. There are some already-recognised opportunities (capable of realisation in the short term) for this, for example by siphoning off a proportion of traffic at ‘remote’ P&R sites at Witney and/or Eynsham. Similarly, providing bus priority measures and improved public transport services along the A40 would undoubtedly reduce the volume of traffic negotiating these roundabouts.

The Wolvercote scheme apparently makes no allowance for the traffic alleviation which would result from the planned construction of an A40-A44-(A34) link road likely to be delivered as part of the Northern Gateway development. If these schemes were included as part of the strategic context this would open the way to designs more sympathetic to non-car travel modes at the two roundabouts. There is no logic to implementing a scheme at Wolvercote based on the full projected traffic volumes, which could be rendered obsolete within a year or two by an A40 improvement package with a traffic reduction component.

The suggestion that further modifications to the roundabouts to improve conditions for non-car modes might be introduced at a later stage, as was suggested at the exhibition of the current proposals is neither plausible nor representative of efficient utilisation of resources. The proposals as they stand represent tactical adjustments without strategic context.

Secondly, the complete absence of any background data, explanation or justification of the proposals means that, this constitutes simply a presentation of proposals rather than any meaningful consultation. As examples, no data quantifying existing conditions, no explanation of policy context, no evidence of consideration of alternative solutions, no identification of predicted impacts and no assessment of their relationship to policy objectives (over the wider affected area, not just at the two roundabouts) has been provided. We have queried the availability of this type of information for this consultation, but, regrettably, have received no response or acknowledgement from Council officers. It is impossible to make properly meaningful assessments of the acceptability of the proposals when they comprise only diagrammatic representations of the intended physical works, with no supporting data of any kind. Accordingly our comments are necessarily made in a situation which we regard as unsatisfactory, despite our efforts at obtaining clarification.

Thirdly, this presentation fails to make clear whether it is anticipated that travel, traffic conditions (i.e. journey times, safety and congestion levels) and environmental conditions within the city can be improved, whilst at the same time catering for increased volumes of traffic. The implications from these proposals and from work elsewhere by the County suggests not, despite such improvements being among the specific objectives of the project. The consequence of failure in this regard is likely to be the speeding up of traffic flows here, but extended queueing and worse environmental conditions elsewhere.

Specific observations

Slide 2

“Our proposed improvements are designed to address the current problems and ensure development in Oxfordshire does not lead to worse problems in future.” The consultation documentation is confusing since, in discussion with officers, it transpires that the proposals are not intended to, and do not in fact make provision for access to or from the proposed Northern Gateway, or the Wolvercote Paper Mill developments, as examples. There is also no information provided on how the proposed improvements are “designed to ….. ensure development in Oxfordshire does not lead to worse problems in the future.” With no detail provided, this statement is meaningless. The absence of any information on how the proposals shown have been developed as a solution to the current and future potential problems really precludes meaningful assessment of the proposals as shown. This is exacerbated by the absence of any measure of the expected effects of implementation of these proposals, quantified or otherwise.

There is no mention of whether, or how the proposals shown here relate to the Oxford Transport Strategy, the amendments to LTP3, the development of LTP4, or the County Council commitment to encouragement of active travel (walking and cycling) as a contributor to improved health, as well as to congestion reduction and environmental improvement. There is no mention of whether or how consideration has been given to such assertions as that of the House of Commons Transport Committee (2014-2015 Report), that: “Infrastructure projects should consider cycling from the earliest stage, with road design treating cycling as a valid form of transport, rather than as an afterthought”.

Slide 4

It is not clear whether the developments referred to on the plan are the only ones which have been taken into account in preparing the roundabout proposals, or are illustrative of the kind of developments which are anticipated. There are many more which should be considered, such as the Wolvercote Paper Mill site, the Ewert House/Diamond Place development, the Summertown Strategic site, Westgate, West Way, Botley, a potential new football stadium at Water Eaton etc. etc. The statement “….. proposals shown in this consultation have taken into account known local and wider developments …..” gives no clue as to precisely what developments have been considered, nor how they have been taken into account. Discussions with officers failed to elicit any clarification, except that little actual modelling has been carried out to date, apparently, either of motor vehicle, bus, bicycle or pedestrian traffic, and no specific provision is made for traffic generated by the Northern Gateway development, for example. This suggests that the detailed plans shown may bear little resemblance to any measures ultimately adopted.

There is no indication that any consideration has been given to the effects of the proposed alterations at these roundabouts on traffic conditions anywhere else. This should include, for example, the areas of the communities of Wolvercote, Cutteslowe, Summertown etc., as well as the roads and junctions more remote from the roundabouts themselves.

Slide 5

Many of the stated objectives are so general as to be meaningless, and/or their pursuit is not borne out by the designs shown. For example, “Reduce journey times” is stated as the first objective, but it is not clear for what journeys this applies, nor to what modes of transport; there are no design features shown which might “Improve bus connectivity”, such as dedicated bus lanes or priority traffic light phasing. Since there is a separate reference to safety, “Improve pedestrian and cycle access” might be presumed to suggest more convenient, faster access, yet the proposals indicate that most journeys will necessitate multiple light-controlled crossings and negotiation of highly convoluted routes, whose attractiveness, especially to current non-cyclists, is likely to be highly questionable. The objective to “Protect the local environment” is so vague and over-arching that it has no meaning at all. Whilst the objectives set out in Slide 5 are vague, the proposals shown do not even reflect these objectives adequately.

It is stated that there is an objective to “Protect the A34 from additional congestion”, but no mention of doing the same for any other roads, which are mostly suburban distributors transecting residential communities, for whom congestion and pollution are serious problems. Furthermore, there is no indication of just how the proposals shown might “Protect the A34…..”.

It is noted that providing increased capacity to accommodate increased traffic is not stated as an objective, but there is no reference to the possibility that the proposals will simply have the effect of increasing traffic flows, while congestion and environmental degradation remain at current, levels, or may deteriorate further, both here, and at other affected locations; this is, of course, a common phenomenon – traffic volumes simply expand to maintain existing levels of congestion, or journey times.

Slide 6

No explanation is offered for the adoption of the proposals shown, for example for directing pedestrian and cycle traffic through the central island. This solution is directly at odds with the principle almost universally adopted in Holland (renowned for its cycling provision), where cycle routes are typically provided on a concentric track around the outside of the roundabout. The proposals shown here result in very convoluted routeing and multiple light-controlled junctions, which do nothing to encourage cycling, do not make for an attractive environment for walkers, and may well result in increasing frustration for motor vehicle users, cyclists and pedestrians alike.

The plan shows serious anomalies in that the A40 east and west of the roundabout has light-controlled pedestrian crossings on half the dual carriageway only, with no means for continuing a journey beyond the central carriageway reservation, without dodging uncontrolled traffic. Inconsistently, the similar crossings of the A44 and Woodstock Road entries to the roundabout are shown with light-controlled crossings of both carriageways. It is presumed that the plan incorporates a number of errors, which is regrettable since it precludes sensible consideration of the proposals.

Likewise, the pedestrian/cycle route across the centre of the roundabout can only be reached by uncontrolled crossings of the vehicle flows negotiating the roundabout itself. This is completely implausible as a satisfactory arrangement, not least because of safety – mixing bikes, pedestrians, mobility scooters, push-chairs, motor-bikes, cars, trucks and buses in circumstances where vehicles are simultaneously manoeuvring (‘weaving’) on the roundabout and seeking exit points, with no controls whatsoever is very obviously a recipe for disaster.

Even if all four of the crossings shown are modified to be light-controlled, whilst safety may be improved, this arrangement looks far from satisfactory, because of the potential inconvenience and delays to all modes. It is difficult to see why any pedestrians or cyclists might consider that taking a route via the roundabout central island could be attractive.

A further anomaly is the absence of any off-highway route for eastbound cyclists between the A44 and the A40, i.e. to link from Five Mile Drive to the Sunderland Avenue service road. This is likely to be a highly preferred route following the opening of the Water Eaton Parkway station; the arrangement shown suggests that cyclists would be required to negotiate a short sector of the roundabout carriageway in order to follow it. It is assumed that this is another error in the preparation of the plan.

No bus lanes are shown on the approach to, or through the roundabout, on any of the roads; there is thus no indication of any measure which might contribute to the stated objective of improving bus connectivity. Such improvement could be instrumental in reducing traffic flows, congestion and pollution.

It is not satisfactory that no provision is made for southbound cycle or pedestrian traffic on the east side of the A44. The development of the Northern Gateway employment area and the location of the existing Pear Tree Park & Ride site, together with the development of the Water Eaton rail station and the closing of Five Mile Drive to motor vehicles all suggest that there would be considerable cycle traffic using the A44 and Five Mile Drive. As shown, users of this route would have to negotiate 4 sets of light-controlled crossings, causing delays and inconvenience not only to the cyclists and pedestrians, but to buses and other road vehicles as well. Provision of dedicated pedestrian/cycle lanes on the east side of the A44 would eliminate this defect in the current design.

Slide 7

As with the Wolvercote roundabout, no explanation is provided for the adoption of the solution shown, routeing pedestrians and cyclists through the centre of the roundabout. It is not evident that consideration has been given to any other options, why this particular option has been adopted, or why pedestrians and cyclists might consider the routes shown attractive. On the face of it, the routeing for cyclists and pedestrians is convoluted and inconvenient. For example, anyone travelling southwards on the east side of the Banbury Road would have to negotiate six sets of traffic-light controlled crossings to simply cross the A40.

Unlike at the Wolvercote roundabout, light-controlled pedestrian/cycle crossings are provided throughout, but the ‘hamburger’ configuration results in the requirement for 8 new sets of light-controlled crossings; the logic for this is not clear.

The geometry of the roundabout and the positions of the light-controlled crossings in the centre appear likely to result in frequent total blockage of the roundabout, since even north-south traffic would be obstructed by vehicles waiting at red lights on the ‘hamburger’ elements, after the arrival of very few vehicles, owing to the very short waiting lengths at the central crossings.

It is not clear why the existing light-controlled crossing of the A40 around 70m west of the roundabout is retained, when all motor traffic travelling either east or west will be controlled by new light-controlled crossings at the roundabout itself. It may be more logical to re-position the existing crossing.

There is no indication whether or not it is proposed to retain the light-controlled crossing on Banbury Road 100m north of the roundabout (adjacent to the Harefields access, and not shown on the proposals plan). All traffic on the Banbury Road will be regulated by new light-controlled crossings at the roundabout itself, but the existing crossing at Harefields is an important element of National Cycle Network Route 51. If it were to be removed or altered, consideration must be given to the layout of this part of Route 51, in consultation with Sustrans.