The recent Surrey Highways submission to the 60 dwelling scheme along the Crawley Down Road [DM/22/3214] dated 15th December 2022, sheds new light on the validity of Transport Assessments which continue to assume improvements to the A264/A22 Felbridge junction.

Infrastructure First fully appreciates the modest nature of the predicted increase in traffic from the current scheme. However, there have been NO improvements to the Felbridge junction despite the additional traffic impact from several hundred occupied dwellings that should have already been mitigated by them.

Until the committed junction improvements have been delivered, further nearby development schemes could, and should, be legitimately REFUSED or at least subject to Grampian conditions which guarantee that committed improvements are actually delivered.

We understand the difficulty faced by decision makers in resisting schemes where the  Competent Highways Authority has not objected, but there is a strong case for long standing committed improvements to the Felbridge junction come before further schemes are approved.

As long ago as 2011, the 100 dwelling scheme West of Imberhorne Farm was approved on the basis that synchronisation of signals at the Imberhorne and Felbridge junctions would mitigate an otherwise unacceptable traffic impact. Surrey Highways confirm that the synchronisation has still not been implemented!    

The Atkin’s ‘Do Minimum’ improvements to the Felbridge junction have been included in the West Sussex Highways Transport Plan since 2012; and included as mitigation in all Mid Sussex Strategic Transport Plans since then.

From 2016, the Atkin’s improvements to the Felbridge junction have been used as mitigation in the approval of several more hundred dwellings … at Hill Place Farm, 27 Copthorne Road and 15/35 Crawley Down Road.

The traffic from these developments is already impacting the Felbridge junction but the Atkin’s ‘Do Minimum’ improvements remain on the drawing board, with little likelihood of them being implemented, due to Surrey Highway’s safety concerns.

All these schemes, including the scheme currently under consideration, rely on the Atkin’s ‘Do Minimum’ improvements in their transport assessments; and the modelled utilisation figures therefore understate the true traffic demand on the Felbridge junction.  This goes some way to explaining why current road users are experiencing worsening delays.

In their Highways Note dated 15th February 2023, i-Transport are confident that a highways intervention will always be delivered where the funding is secured. History shows that this is just not the case.

The same misplaced confidence was shared by the appeal inspectors for the 200 dwelling scheme at Hill Place Farm and the 63 dwelling scheme at 15/35 Crawley Down Road Inquiries.

Paragraph 263 of the Hill Place Farm appeal ruling, showed that the Inspector considered there to be sufficient certainty that the Atkin’s improvement to the Felbridge junction would be delivered. Indeed, West Sussex Highway’s evidence paper to the inquiry, dated 27th October 2016 [ref LPA7] stated that they couldn’t foresee any impediments to its delivery …

“There are no identified impediments to the proposed improvements being undertaken should the funding associated with the grant of a planning consent at Hill Place Farm be available.”

Paragraph 41 of the 15/35 Crawley Down Road appeal ruling shows that the Inspector’s decision was influenced by the earlier appeal ruling …

“The 200 dwelling Hill Place Farm scheme was approved on the basis that an improvement scheme at the A264/A22 junction would go ahead. The Inspector (and subsequently the Secretary of State) were satisfied that the associated planning agreement gave sufficient certainty a scheme would be delivered, and no Grampian condition was required. The present appeal, for a lesser number of dwellings should therefore be considered on the same basis.”

We know that Surrey Highways implemented a scheme similar to the Atkin’s ‘Do Minimum’ junction improvement some 30 years ago, but it was quickly withdrawn due to safety concerns and an unacceptable increase in vehicle collisions. Infrastructure First has seen a copy of the minutes from a meeting between Cllr Jeremy Clarke and Mike Green (SCC Transport Development Manager), William Bryans (SCC Transport Studies) and others dated 13th January 2022 …

“To get a common understanding of the previous implementation of the 2-lanes turning south from the A264 (2012 Atkins Do Minimum) and why it was abandoned within weeks: Cllr Clarke explained that this was implemented in the mid 1990’s and withdrawn almost immediately. His recollection was that there were a large number of low speed accidents including a vehicle in the spa shop window and another under an articulated lorry. No significant injuries, but the junction was regularly blocked. Thus, it was withdrawn. SCC Highways confirmed in writing (July 2018) that they were aware of its previous implementation and withdrawal. However, this is the only proposed scheme in the public domain and is being relied upon as the mitigation of the already approved houses at Hill Place Farm, 17 Copthorne Road, 11a Crawley Down Road and 15 Crawley Down Road [total of 326 dwellings]. William Byrne said that he had raised concerns about the proposed 2 lanes turning south in the past.”

Whether an alternative solution for the Felbridge junction can be found; which is affordable and agreeable to both West Sussex and Surrey Highways is not yet known. and is currently the subject of a new Atkins study due to start in the coming months.

What we do know however, is that the study to identify options to improve junction capacity and pedestrian safety undertaken by WSP in 2019 was ultimately unsuccessful.  

In their September 2020 regulation 18 response to the recently adopted DPD, West Sussex Highways raised the possibility that a scheme to improve the Felbridge junction may not be deliverable … 

“There is currently no scheme identified to improve the Felbridge junction that achieves all objectives and that all parties consider to be deliverable.  Therefore, in the absence of evidence to the contrary, the County Council consider that the Site Allocations DPD should also acknowledge the possibility that improvements may not be deliverable at the Felbridge junction.” 

In their most recent consultation response to the further development of 60 dwellings along the Crawley Down Road [DM/22/3214], Surrey Highways have concluded that it is no longer safe to approve housing schemes on the assumption that additional traffic will be mitigated by improvements to the Felbridge junction.

“It should not be assumed that a solution will be in place for the A22/A264 junction that can mitigate the adverse impact of the development. The TA should therefore consider the current junction without mitigation.” 

As it stands there are no identified improvements to the Felbridge junction acceptable to both Highways Authorities. Even if the latest Atkins study identifies an agreeable solution, it is by no means clear that it will be affordable, on the basis of Surrey Highways unsuccessful bid to the Housing Infrastructure Fund.

The March 2019 bid for the A22/A264 Felbridge junction [widening and adding ‘jet lanes’, with associated signal reconfiguration and improved pedestrian crossing facilities] was for   £11.1m. A recent Freedom of Information Request to West Sussex Highways revealed that the amount currently secured from s106 undertakings, in relation to general A22 improvements, to be at most £1.1m.

Infrastructure First accepts that the predicted traffic from the current 20 dwelling scheme is unlikely to have a severe impact on its own. However, the same cannot be said for the cumulative impact from the several hundred dwellings already occupied and for which the required highways mitigation at the Felbridge junction has NOT been delivered.

On behalf of all road users that continue to experience unacceptable delays along the A22 corridor into East Grinstead, please consider the failure to deliver committed improvements to the Felbridge junction as weighing negatively in the planning balance.

Paul Tucker

For Infrastructure First