Monday, 13 April 2015

Objections to Central Square development 14/02405/MJR

Objections to Central Square development 14/02405/MJR from Cardiff Bus Users  
DEMOLITION OF MARLAND HOUSE, FULL PLANNING APPLICATION FOR MEDIA CENTRE, GROUND FLOOR RETAIL AND CAFE UNITS (USE CLASSES A1 A2 A3) ROOF-TOP PLANT, SATELLITE DISHES AND PHOTO VOLTAIC PANELS (PLOT 3) BASEMENT CAR PARKING TO PLOTS 2 AND 3, PUBLIC REALM AND LANDSCAPING, AND RELATED INFRASTRUCTURE AND ENGINEERING WORKS. OUTLINE APPLICATION FOR UP TO 14,550SQM GROSS CLASS B1 (A) OFFICE FLOORSPACE (PLOT2) WITH ALL MATTERS RESERVED EXCEPT ACCESS. | LAND TO NORTH OF CARDIFF CENTRAL RAILWAY STATION INCORPORATING CARDIFF BUS STATION, MARLAND HOUSE AND WOOD STREET, CARDIFF

Objections to Central Square development
We note the difference between the outline masterplan site and the detailed red-line site as shown in ES Ch.N, Appendix N2. If their boundaries have been changed, the application needs re-publishing (no hiding of such fundamentals in the many new documents and updates).

This development site being highly accessible to non-car modes to be used for travel intensive uses
This principle in Planning Policy Wales 8.6.2 should be implemented by the LDP; however, as this is still under examination, awaiting Cardiff Council’s responses to the Inspectors ‘action points’ including this site, this principle has to be met in the present planning application – reallocating a substantial part of the site for a full transport interchange and other travel intensive uses if necessary, compared with the plans of Cardiff council as joint developer.
The applicant to be asked for evidence that its proposed uses for offices, hotel and student accommodation meet the “travel intensive” criterion.
Site in the Business Enterprise Zone
The site is important in the Cardiff central enterprise zone. 
The applicant should be asked for information justifying the proposed uses in relation to the purposes (Financial and Professional Services) for which this enterprise zone is designated.
Mitigation measures
Planning Policy Wales 8.6.3 requires account of the willingness of developers to overcome transport objections, including adverse effects on the safety and convenience of pedestrians using the transport interchange. 
The applicant should be asked for evidence on the coach station that they say should be provided off-site, elsewhere, on options for running the Cardiff Region Metro through the site and having a station in the transport interchange, and on putting the bus station access/egress at a critical position across the major pedestrian route to the transport interchange and rail station.
Provide a new Bus Station/Interchange on the Marland House site first
Planning Policy Wales 8.7.3 specifies: Where transport improvements will be needed to enable the proposal to go ahead, these should normally be provided first.
Explanation for not following policy must be provided.  Cardiff Council knew of the policy, so were wrong as developers to market the bus station site without making requiring a new bus station first.
The council as planning authority should make it a pre-condition of any planning permission in this case.
Failure to comply with policy for a Regional Transport Interchange
None is provided in the Outline plans; nothing for a coach station and nothing for the future Cardiff-region Metro options. This fails to comply with the Wales Transport Plan.
As they (CGD report) propose a coach station site elsewhere, the developers should provide information on one or more alternative sites, with costs and money to cover it in whole or part.
Accesses onto Wood St are inadequately specified
These are shown for detailed planning permission as they should be, but not prescribed.  The SGD/AECOM report specifies five options including changes to the Westgate Street access (possibly two-way for buses, possibly banned for non-buses) and Havelock St access (possibly blocked off, possibly for reversed flow cars).  Definite plans in detail are needed, with a preferred option and explanation of what peak bus flows could be accommodated.
Bus station access/egress onto Wood St appears unacceptable
·         Conflict with pedestrian flows, which is already a problem at the adjacent St Marys Street corner. 
·         Emerging buses would be obstructed by incoming right-turning buses ( queueing tend to back up through the Havelock St junction) and by buses from St Marys St right-turning into Westgate St (if Havelock St closed).
  • Bus Station access/egress will be substantially worsened compared with present in terms of congestion and slowness, which are currently over slow and inefficient;
  • The AECOM study of options for ‘dog-leg’ egress (instead of the straight cross between Marland St and Havelock St) show uncertainty, even with substantial changes in traffic routing which they consider (even stopping non-bus traffic southwards on Westgate St)
The applicant needs to specify pedestrian routes to and from the Wood St and Westgate St bus-stops/terminals; secondly to provide evidence that bus routing layouts would work and what non-bus traffic might need to be diverted or excluded.  As the area is included within the red-line for detailed planning permission, they must specify which option they will choose and implement.
The north-side pavement outside O’Neills pub is often crowded; the needed widening should be provided within the current proposals (being within the red-line for detailed planning).
Inadequate Replacement Bus Station (outline)
Too little space is allocated in the Masterplan to replace current uses – SGD/Aecom reports say will not take coach services and allow only 15% extra buses, not the doubling implied by the 50:50 modal split of the LDP.
·          Replacement Bus Station (outline) does not allow for (any of) the current nearby bus terminals and laybys on-street  (in Wood St, lower Westgate St  and lower St Mary’s Street) so does not deliver the Central Bus Interchange
·         The replacement Bus Station is not the “world class integrated transport facility” defined in the SGD report and promised in Cabinet statements: “a defining community feature instilling a sense of pride in users and the wider community”. The outline application should meet the SGD requirements for direct convenient routes and visibility; adequate access points, spatial capacity for all station functions, appropriate space for all vehicles (including layover) and passengers; well integrated with the surrounding urban context - face onto Central Square and integrate with movements across it; allow spatial capacity to meet predicted future demand,
Steer Davies Gleeve report(SDG)  Oct’14 Central Square; new bus facility and potential for an integrated transport hub).
The applicant should be asked for an assessment of design and connectivity relative to the SGD requirements mentioned above; also an assessment of the projected numbers of buses and space required under the LDP and Local Transport Plan (LTP) plans to meet the 50:50 modal split (approx. doubling of city and regional buses).
The Five options in the Central Square, Cardiff Transport Assessment are all unacceptable
The development of Central Square will require the closure of the bus station. Five relocation options are to be considered:
1 Northern bus station on NCP car park site, keeping Arriva car park and Saunders Road taxi rank as existing;
2 Northern bus station on NCP car park site, removing Arriva car park and Saunders Road taxi rank;
3 Split bus station, facility on the north on NCP car park site (keeping Arriva car park and Saunders Road taxi rank as existing) and facility on the south (located on current network rail car park);
4 Southern bus station only, situated on the current Network Rail car park; and
5 No bus station, i.e. operation once the bus station is closed without a replacement facility and utilising on-road stops.
  • The NCP site is too small for a world class bus station
  • None includes use of (part of) the Marland House site, as agreed by Cabinet in December
  • This approach relies on continued use of Wood Street and Westgate Street as bus terminals, though the facilities were supposedly temporary and are quite inadequate.  They were also part of the anti-clockwise ‘Bus Box’ system which is pretty well defunct.
  • The plans do not allow bus terminals in Wood St etc. to be pulled back into the new Bus Station and Integrated transport hub.
  • C’llr Patel in charge of reshaping Cardiff’s bus routes gave an undertaking (SW Echo of 27 March) that passengers will definitely be able to board and get off buses at a new central bus station to be built in the city centre; the public understands that to mean most if not all the buses going through Central Square.

Use of out-of-date guidance on Walking by the Applicants
The Environmental Statement (October 2014) Chapter C Transportation 31084/JCO/EX says                                 “CIHT guidance states that 400m is an acceptable distance to walk to a bus stop. From Central Square both Wood Street and St Mary Street are within 400m, with bus stops located on each road from Central Square, Cardiff”
  • The CIHT guidance is out-of-date (from 2000).  The new CIHT guidance March 2015 Designing for Walking refers to planning for walking in the Active Travel (Wales) guidelines and the DfT’s Manual for Streets.
  • Active Travel Chapter  5 Section 1  Network Planning For Walking takes precedence. http://gov.wales/docs/det/consultation/140430-active-travel-design-guidance.pdf. The Manual for streets has relevant sections:
  • Bus stops 6.5.9 It is essential to consider the siting of public transport stops and related pedestrian desire lines at an early stage of design. Close co-operation is required between public transport operators, the local authorities and the developer. 6.5.10 First and foremost, the siting of bus stops should be based on trying to ensure they can be easily accessed on foot. Their precise location will depend on other issues, such as the need to avoid noise nuisance, visibility requirements, and the convenience of pedestrians and cyclists. Routes to bus stops must be accessible by disabled people
  • 2.4 Walking distances Walking distances were researched in some detail in the late 1980s and, based on the findings from these studies, the following are recommended:               Impaired group - Recommended distance limit without a rest                                                     a. Wheelchair users  150m b. Visually impaired 150m c. Mobility impaired using stick 50m d. Mobility impaired without walking aid 100m from inclusive mobility https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/3695/inclusive-mobility.pdf
We conclude the applicants need to submit amended material that covers the current policy guidance on Walking.

Commercial developments preventing the world-class bus station and Regional Interchange
  • Plot 9 on the corner of Wood Street and Marland Street is within the red-line for detailed planning permission; details must be provided to allow a decision
  • Plot 9 in respect of outline permission for a building prevents a better option for Bus Station egress virtually opposite Havelock Place – better for bus movement, for distance from the Westgate St junction with bus station entrance, and for pedestrian access from Wood St into the Bus station.
  • The  500,000 sq ft of new commercial developments on Plots 9-11 (of the Foster Ptnrs plan for Rightacres) appear to need rear access via Saunders Road, which interferes with the buses and their efficient operation.  They take most or all the frontage onto Central Sq, contrary to the SDG’s requirement for the frontage to contain the Bus station as a defining community feature.
No space provided for options for the Cardiff City Region Metro
  • no space on Wood Street for Metro tram-train lines and Platforms, which does not meet Council and other documents showing such a metro running along Wood St.
  •  no consideration of Metro running via Saunders Road across Central Sq., with its clear advantages for mode-interchange, event-day running and freeing from traffic congestion on the Westgate St/  Wood St/ St Mary’s Street junctions
Congestion
  • No evidence re. congestion over the Wood St bridge and in Tudor St (used as bus terminal) from increased buses plus Metro-tram, which may require restriction of other traffic including to the proposed developments
  • As “substantial/moderate adverse” changes to traffic are predicted on Wood Street, including the critical section from Havelock St to St Marys Street, the applicants should provide an assessment of the implied congestion and increased vehicles crossing the main pedestrian routes.
Compliance with Active Travel Act and the road-user hierarchy
In view of the detriment to pedestrian movements particularly due to the proposed Bus Station access and egress, the applicant needs to show why this layout was chosen rather than an alternative that gives due priority to pedestrian use of the Marland St to St Marys Street roadspace on Wood Street
Operation during street closures, ‘event’ days and Fri/Sat evenings
  • no evidence that the Bus Station (and Regional Transport Interchange) could operate during ‘event’ day street closures
  •  no evidence that Bus Services could continue during evening closure of lower St Mary’s Street (though Westgate Lane provides a possible route)
  • no evidence on Bus Station access/egress during event day closures, presumably intended via Saunders Rd, including the rear business access and car-park access via Saunders Road, to show compatible with bus (and metro) access.
  • no evidence on buses using the Wood St bridge running instead during event day closures via Clare Rd and Penarth Rd to the Bus Station/interchange
Air Pollution Potentially Unacceptable
  • no measures to mitigate the worsened traffic pollution in the St Marys Street/Westgate St AQMA, currently in excess of legal limits; no plans that worsen this overall should be accepted (traffic re-routing; reducing taxi access/waiting; funding electric/hybrid buses; closing a Westgate St ms carpark are all feasible measures that have not been considered). The 2011 ‘Action Plan’ measures are hardly being pursued, so can be ignored for projections 
  • no evidence given on the likely significant air pollution in the confined bus station space; the responsible council Officer failed to mention this issue in his request for information
  • The traffic emission modelling uses poor out-of-date assumptions on NO2 emissions, despite the AQMA being designated for illegally high NO2. it is well-established that Defra projections of reducing vehicle NO2 are invalidated by modern measurements of real vehicle emissions far higher than the Euro standards assumed.
  • The NO2 modelling makes somewhat arbitrary choices of street canyon and non-canyon for parts of Westgate St (and others), which could be part of the reason for poor agreement with NO2 monitor data. All the Westgate St points (2,5,7,12,14) in Table G5.8 are substantially higher than t
  • he modelling, so that future predictions are likely to badly underestimate.
     
The applicant should be asked for information on mitigation (measures as above; they suggest only ‘travel plans’) to reduce illegal levels in the AQMA and likely within the confined bus-station space.
Car Parking
PPW  8.4 Managing traffic and parking says “refuse planning permission for public and private car parks which do not meet the strategic aims of the development plan and RTP (and LTP)”.
“Within town centres priority should be given to walking, cycling, public transport and delivery vehicles through the reallocation of road space”.  Including parking (other than minimal disabled parking) for any of the buildings adds unnecessary traffic on Wood Street etc. so goes contrary to this policy. “Minimum parking standards are no longer appropriate”. As Cardiff has so far failed to follow policy to “develop an integrated strategy on parking to support the overall transport and locational policies of the development plan”, parking levels for the Central Square development should be minimised in accord with needs of the limited road space for active travel modes and need to cut back central traffic congestion and pollution.  The Masterplan needs changing to say this.
“Car parking provision is a major influence on the choice of means of transport and the pattern of development”.  Provision for car parking will encourage car use rather than public transport.  The total of 350 spaces accessed from Saunders Rd (pretending to replace the NCP car park, bought out with public money) are unnecessary for a site so well served by public transport.
The applicants should provide evidence on a) the minimal level of disabled parking required for each block/Plot, and b) alternative locations for the total car-parking ‘needed’, eg. South of the rail station.
    • The applicants give no backing for the parking numbers chosen (except for the Hotel).  Minimal car parking in these developments should be part of the masterplan, under priority for public transport and pedestrian/cycle access to it (Active Travel Act; Wales Transport Policy, PPW 8.4 etc.) and need
    •  The allocation of spaces in the proposed Gt Western St carpark with 213 spaces for the BBC (as well as their underbuilding parking) but 80 for the Hotel and 57 for the retail and office development (bigger sq ftage than the BBC) combined shows unfair/unprincipled distribution,
    • car parking for the businesses and BBC is better provided to the south of the rail station, where interference with bus and metro running would be far less.
    People flows
    In default of evidence on pedestrian numbers, flows and pinch point, we make qualitative points:
    • The St Marys St/Wood St/Westgate St intersection would have high flows; pavements past the O’Neill pub are currently inadequate
    • Bus station access/egress  into Westgate Lane would give extreme disruption to flows
    • Bus station access routes  for passengers need to be defined
    • the Saunders Rd access is important for pedestrians and cyclists, so give them priority and limit vehicular traffic and roadspace
    • the Penarth Road under-b
    • ridge is important for pedestrians; the west-side pavement needs widening as part of the development.
    Detailed Plans needed for pedestrian routes and new/relocated bus stops within the masterplan area
    • The Active Travel legislation states:  “Public transport interchanges should be considered a very high priority in the planning of the pedestrian network, following the guidance contained in Chapter 5 (Network planning http://gov.wales/docs/det/consultation/140430-active-travel-design-guidance.pdf).  It may also be necessary to change the location of bus stops, or to introduce new ones, to reduce walk distances and improve accessibility, particularly where new development is planned.”
    • Bus stops in Wood Street need relocating to reduce walk distances and improve accessibility, which should be shown in the plans
    • The applicant/Cardiff council need to undertake a consultation programme under the Active Travel Act, which includes political commitment, skilled delivery teams, engagement, encouragement and promotion.
    Security 
    The BBC office at Llandaf is like Welsh government and assembly buildings a potential target for terrorist attack.  The BBC’s is currently protected by rising bollards and main approach via steps that prevent approach by bomb-carrying vehicles. 
    The applicants need to provide evidence that security is designed into the proposals, and measures that could be effective in this open urban situation with high traffic  on public streets.
    Further and genuine Consultation needed
    public interest in the future of Central Sq, especially in the replacement bus station, is high.  Yet the public does not generally know consultation is supposed to be proceeding via the planning application.  Only one individual has written in.   The reasons are not only the difficulty in accessing the over 180 documents, but also the lack of publicity for the plans and the failure of the applicants to mount any general consultation events or exhibitions.  Involving selected stakeholders, but excluding Cardiff Bus-Users and other community/interest groups, does not meet the key principle in Planning Policy Wales:
    • engagement and involvement, ensuring that everyone has the chance to obtain information, see how decisions are made and take part in decision-making;
    requires plans to consider well-being and sustainable development and specifically
    • to involve those with an interest in the objectives, by seeking their views and taking them into account.
    The applicant should be required to mount some open public consultation, as usual for major planning applications.


    Objections to Central Square development 14/02405/MJR from Cardiff Bus Users  
    Contact Anne Greagsby

    Note the difference between the outline master plan site and the detailed red-line site as shown in ES Ch.N, Appendix N2. If their boundaries have been changed,
    the application needs re-publishing
    (no hiding of such fundamentals in the many new documents and updates).

    Cyclist Objections to Central Sq proposals

    Cycling facilities are promised in the masterplan for outline permission, as is the Saunders Road route past the Great Western pub on the east of the station? But Wood Street up to St Mary’s Street is up for detailed planning permission.  Also the outline plans for the bus station leave all exsisting buses outside, using the Westgate St to lower St Marys Street route.  The Metro is not mentioned at all (!!) and would be run along Wood Street, joining to the N-S route running on St Marys Street under one (perhaps favourite) option.  The full length of St Marys Street is supposed to be a cycle-route; remember they said bikes were to use the pavements in lower SMS to avoid the other traffic!

    Cycling objections
    • The Cycle parking promised in front of the Rail Station is not estimated or allocated space; the present stands are over-used, but their numbers are no guide as to the numbers needed (suppressed demand and projected expansion). Cities like Bristol could be an example.  A number like 200 should be designed in, which requires significant space and design to fit in the Square – not tucked away at the side or in front of a Bus Station concourse (with maximum conflict with pedestrians) 
    • Management, maintenance and security-supervision for such cycle parking needs to be guaranteed by the developers.   
    • Bus station capacity inadequate to pull the lower SMS buses into the Bus station, needed to give space for cyclists and a Metro-tram system; the tram-lines for a Metro are an additional hazard for cyclists, so minimising other traffic is important.
    • The Bus station access/egress from Wood Street (at Gt Western Lane) crosses the Wood St cycle-link to SMS at a critical point with high pedestrian flows.  The short ‘dog-legs’ for buses exiting to Havelock St or Westgate St forcing large buses to swing around are hazardous and intimidating to cyclists.  
    • Bus station design does not permit running buses on the Westgate St/Gt Western Lane/Saunders Rd alignment to give better separation from cyclists – and is very feasible given the flexibility of the site empty of the NCP Carpark and Marland House.
    • the Wood Street route to SMS is needed as a main pedestrian and cyclist route, not just the route in front of the rail station into Saunders Rd; also a cyclist route from the railstation to SMS across the square/Marland St is needed, with informal separation from main pedestrian flow indicated.
    • Air Pollution: increasing levels of NO2 which are already illegally high is unacceptable.  Buses which are a major source of roadside NO2 are to perhaps double; congestion delays will also increase, but are not included in NO2 projections.  Minimising cyclist (and pedestrian) exposure to air pollution is an important objective – separation of their routes from bus and taxis is best, removing bus and taxi stops from routes also needed. 
    • The proposal to put an extra taxi rank in Wood St is unacceptable on air pollution as well as traffic gounds. The large BBC TV operational high-pollution diesel vehicles (as HGVs also a risk for cyclists) 
    • The proposal for a 350-space car park is unacceptable: Planning Policy Wales 8.4 “Managing traffic and parking - You should refuse planning permission for public and private car parks which do not meet the strategic aims of the development plan and RTP.”​ The strategic aim is to minimise central car-parking (limit to genuine 'disabled') and secure shift to 'sustainable' transport modes.

    ----------------------- 
    14/02405/MJR | DEMOLITION OF MARLAND HOUSE, FULL PLANNING APPLICATION FOR MEDIA CENTRE, GROUND FLOOR RETAIL AND CAFE UNITS (USE CLASSES A1 A2 A3) ROOF-TOP PLANT, SATELLITE DISHES AND PHOTO VOLTAIC PANELS (PLOT 3) BASEMENT CAR PARKING TO PLOTS 2 AND 3, PUBLIC REALM AND LANDSCAPING, AND RELATED INFRASTRUCTURE AND ENGINEERING WORKS. OUTLINE APPLICATION FOR UP TO 14,550SQM GROSS CLASS B1 (A) OFFICE FLOORSPACE (PLOT2) WITH ALL MATTERS RESERVED EXCEPT ACCESS. | LAND TO NORTH OF CARDIFF CENTRAL RAILWAY STATION INCORPORATING CARDIFF BUS STATION, MARLAND HOUSE AND WOOD STREET, CARDIFF

     135,000 sq ft 1 Central Square office building (already permitted, with parking??)
     BBC Wales's 180,000 sq ft headquarters (Parking under blg + 213 parking spaces). [plot 3]
    100,000 sq ft 2 Central Square office development. [plot 2]
    500,000 sq ft commercial developments around new Bus Interchange  = 200,000 sq ft of office space, 100 bedroom hotel, private residential apartments, 30,000 sq ft of retail (ground floor)
    20 storey 250 apartment complex +15 storey 460 student ‘studios’ (The Blades). [plots 4-5?]
    St David's House three mixed commercial use buildings+ ground level retail; 9 storey shown, similar bulk to The Blades     [650 000sqft in plots 4-8 in ES Chapter N]
    Plot 12 bus station + car parking   [No detail in ES Chapter N]
    Plot 13a Office + Retail 36 500sq ft
    Plot 13b  Network Rail office + Retail  29 000sq ft

    Thursday, 2 April 2015

    New dangerous 2.15m lane for buses/fire engines at spot where Karina Menzies was mown down

    New 2.15m traffic lane including the gutter
    Cardiff Labour Council ignores Active Travel guidance with 2.15m lane including the gutter, for buses/fire engines etc   

    What is Labours Cllr Ramesh Patel thinking of, allowing this? Next to the very spot where Karina Menzies was killed  The new road layout and crossing was supposed to make it safer to cross the road at this point but it is more dangerous. 

    This Traffic Lane used by buses and Fire Engines is dangerously narrow - just 2.15 metres including the gutter  as the pictures show,  the newly designed pedestrian crossing at Pendine Corner Cowbridge Road just before the Fire Station. 
    A fire appliance can be up to 2.55 metres wide and the lane is just 2.15 metres including the gutter.   
    This road is very busy during the day, buses, fire engines, and other vehicles are forced to drive next to the kerb on the gutter making it extremely dangerous for cyclists and for pedestrians waiting to cross the road. The traffic comes so close one step out and you're dead.


    New 2.15m traffic lane including the gutter
    is below minimun safe width 
    This is at a crossing on a route to school. 
    2.15 metres including the gutter  is much less than the minimum safe width as you can see from this excerpt from Cardiff Council, Cardiff Cycle Design Guide 

    Active Travel Guidance is 4 metres  minimum on roads with speeds up to 30mph          
    Bus lane widths • 4.5m recommended • 4m preferred minimum • 3m absolute minimum • 3.2m to 3.9m to be avoided

    Labours Councillor Peter Bradbury Cabinet member doesn't seem to have notices the danger or Kevin Brennan.  A elderly man who wanted to raise pedestrain safety as an issue was asked to be quiet or leave the super pact meeting by the labour party chair Sue Leader as she didn't think that was a priority.  

    From Cardiff Council, Cardiff Cycle Design Guide     
    July 2011
    5.5.6 In some instances, multiple lanes are provided to accommodate queuing vehicles and it may be acceptable for vehicles to straddle lanes in free‐flowing periods (as at the approach to traffic signals, or at a right‐turn lane). In this instance it may be possible to reduce lane widths to 2.5m, or even to 2.0m where HGV flows are light.
    5.5.7 Wider lane widths may be required on curves, particularly where flows of large vehicles are significant. Vehicle tracking software can be used to identify the required widths. It is important for reasons of safety that sufficient widths are provided for motor vehicles in these circumstances as substandard widths may result, for example, in cyclists being ‘squeezed’ on the inside of bends.
    5.5.8 Where concerns exist about the use of lane widths less than 3.0 metres, designers can be reassured by the following guidance for trunk roads, where speeds are typically higher and traffic flows (particularly of heavy goods vehicles) greater than will commonly be found on Cardiff’s streets:
    • TD 50/04 (Highways Agency, 2004) permits lane widths as narrow as 2.25 metres in certain circumstances on the approaches to traffic signal stop lines.
    Cardiff Council, Cardiff Cycle Design Guide       July 2011

    Monday, 30 March 2015

    Cardiff Labours Bus Station foul up

    Save our bus station 


    The central Bus Station proposals are ill-formed and inadequate.  The Council refused to answer at the LDP Inquiry and now say it’s deferred till June/July. 
    I hear the foul-up is due to 'major projects' and now Ramesh Patel is carrying the can:

    Labours Ramesh Patel, cabinet member for Transport says the document quoted in the Echo’s front page on Friday is not adopted – but it was commissioned by the Council and changed in accord with Council comments in November 2014 
    •  Submitted to the LDP Inquiry early February, that says Cardiff Bus would use it just for turning buses around and use stops on the street (like the 95 and 96 now use Wood St.)
    • The Masterplan for Central Sq (incl. the current Marland House/Media Centre application) proposes use only by present services (41% of city buses) and no coaches at all. It includes narrowing Wood St and having a taxi rank there, presumably displacing bus stops.
    • The Cabinet decision for use of the Marland House site has been finessed into CAB/14/ 80 Min No 102 Central Bus Interchange – 
    Next Steps RESOLVED: that
    1. .. it be agreed that the new bus interchange will be located as part of the development of the Marland House/NCP Car Park site at Central Square.
      This wording (part of) let them to continue to use the ‘Masterplan’ with inadequate space and accesses (below), instead of a “world-class” bus station on the whole of this side of Central Square.  The new documents posted on 13 March (public ad 26th March) confirm only the NCP-site for buses, limited accesses and nothing for the Metro 

    Capacity much too low in numbers of stands, passenger flows and bus/coach flows
    13/14 stands is too few; their ideas to meet capacity limits are
    • National express etc. coaches to go elsewhere
    • Cardiff Bus to continue or expand use of scattered terminals on-street
    •  Allow  for only 15% expansion of buses, ignoring the LDP’s 50:50 modal split
    •  ‘hot stands’ with services switched to vacant slots and rapid loading, with no layover till time-tabled departure time

    Last-minute reallocation of stands with screens/announcements means people rushing back and forth in a confined space.  Worsened awkward turns from and into Wood Street across main pedestrian flows.  No allowance for Metro along Wood Street/St Marys Street across pedestrian and bus access/egress.  

    Detailed Inadequacies
    • the Cardiff plan for the tram-train Metro issued at the LDP Inquiry runs along Wood St, with a stop opposite Havelock St… no design or space for two-way metro-style platforms (as Manchesters, in evidence to the LDP inquiry)
    • the planning application (demolition of Marland House… + media centre; updates 11 March) shows buildings along the Marland Street frontage to Wood St as present, forcing the access/egress for buses into a restricted area, preventing direct egress into Havelock Street.
    • Buses not normally to use Saunders Road for access (by the Great Western pub), as this is reserved for vehicles to a new car park (incl 213 spaces for the BBC, 100 for new offices) and taxis.
    • During ‘event’ closures, buses would enter/exit via Saunders Road, but the metro-line would be blocked; no provision for Fri/Sat closures of lower St Mary’s Street, though the Saunders Rd-Westgate St route through the bus station appears feasible.
    • no provision for a rail-Metro to join the rail-track, on or alongside Platform 0.
    • A rail-metro cannot run in via the south side of the station as sketched, if only because the low voltage tram could not cross the high-voltage main line.  Cardiff therefore have to leave space for in Saunders Rd/Central Square for this option, as well as on-street options.
    • running the metro via Saunders Road would have advantages for either option, so should be left open in a changed Masterplan.   

    See extracts below from Max Wallis LDP submissions on the Regional transport hub, which includes the site plan in the Masterplan, with Bus Station on the NCP site only, as unchanged since.  Mark Drakeford said he'd consult Kay Powell on whether to seek a call-in of the application on grounds that it would prevent the Regional Transport Interchange, including metro options.  No answer on that yet.

    Hearing Session 2: Infrastructure & Delivery - Wed 14 January 2015                     Max Wallis    https://www.cardiff.gov.uk/ENG/resident/Planning/Local-Development-Plan/Examination/Hearings-Timetable/Session2/Documents/HS2%20%282475%29%20Wallis.pdf
    Central Square attempt to pre-empt an integrated transport interchange
    A new Bus Station in an integrated transport hub has been delayed several times, because the previous Council and this one want maximum space for commercial development on Central Square. Cardiff Council plan to dispose of this publicly-owned land, even though it is not surplus to requirements for an integrated transport hub. They plan to dispose of the land 2 or more years in advance of a new bus station, on the excuse of waiting for leases to expire on the new Marland House site (instead of requiring the BBC/developers to buy out the leases). The Central Sq plans are heavily criticised (Prof Stuart Cole) as not transport-driven but commercial development-driven. The Council publicity denied this but the LTP’s s.19 confirms it. The Council mounted a ‘consultation’ on moving the bus-station off Central Square, as an isolated change unrelated to integration with trains and metro. The Council claims to be in partnership with the developer (www.rightacres.co.uk/capitalsquare/4584419104), but the latter says Rightacres is the exclusive developer of Central Square - Cardiff’s new premier financial and professional services destination at the heart of the Cardiff Enterprise Zone that will set a new standard for city centre regeneration. The 800,000 sq ft development will be office-led, but with a mixture of uses, providing high quality commercial, civic, residential, hotel, leisure and retail space in a carefully planned and managed environment.  A contemporary integrated transport hub will be provided in the immediate vicinity of Capital Square.
    Figure from Central Sq “Masterplan”  CARDIFF_CENTRAL_MASTERPLAN_PART1.pdf

    Figure from Central Sq “Masterplan”  CARDIFF_CENTRAL_MASTERPLAN
     Cardiff Council as property developer has signed a contract that would exclude areas of publicly-owned land being used for transport infrastructure. As planning authority, the Council could reject an application that does not leave proper space for the metro, coach and bus station and joint passenger facilities. The conflict of interest needs the LDP Inspector to intervene and require it to be set in the context of LDP decisions. Rightacres and the Foster partners operating for the BBC are writing the Masterplan, which has been long promised, never made public, but details of the proposed masterplan were leaked in October: www.propertymall.com/property-news/article/37005-Cardiff-Central-SquareMasterplan-unveiled Wood Street… has been completely revamped to create a new boulevard with high quality office buildings either side and the space is designed to accommodate the Metro as and when it comes in to play. The redevelopment project will include unrivalled local and international transport links, the latest in sustainable design and a vibrant mix of business, retail, leisure and public spaces.
    The Council has now accepted a planning application for the BBC building with a masterplan that ignores requirements for integrating a metro station into the ‘integrated transport hub’, and expects to push the plan through before the LDP inquiry reports. I’d ask the inspector to issue an interim decision to stop this premature decision that pre-empts sensible planning; alternatively to ask the Welsh Government to call in the planning application.
    The Central Bus Station and continual delays in delivering a new one as part of an integrated transport interchange goes contrary to Welsh and City policies. The LDP’s half sentence in clause j of objectives 1 (economic needs) "improving the city’s key transport hub... " and the LTP’s half sentence in s.19 “This will be further enhanced by … the relocation of the Central Bus Station” show the lack of regard to public transport.
    The earlier discussions show Cardiff Council was set on providing a small capacity bus station with fewer stands (19-22, compared with 26) and about 3 layby positions (smaller than eg. Swansea and Newport). Hull has a recently-built integrated bus/train station and over 20 stands for smaller population (250 000 and no city-region). Cardiff planners did not allow space for expanding buses with population growth and modal shift (75% as above; less if the Metro takes a fraction). Press reports still talk of a smaller bus station though there’s no official report. The LTP (and LDP) give no figures for capacity. The Council planners apparently do not want to provide for long-distance coaches, though National Express said they want to stay. The following sentence in the LTP’s 3.1.5 is revealing “CCC will continue to facilitate the high profile use of Cardiff Bus Station by Traws Cymru services” This special regard to the Airport coach (and a daily bus to Llandrindod/Newtown,) highly subsidised by the WG, indicates an intention not to facilitate National Express and Megabus.
    A new integrated transport hub as an ‘economic and social need’ requires extra clauses under objective 3: To deliver economic and social needs in a co-ordinated way that respects Cardiff’s environment and responds to the challenges of climate change. I propose adding
    ** to promote public transport as a means to achieve environmental objectives, to assist in relieving congestion and to encourage social inclusion
    ** to build an integrated transport interchange including a new bus station on Central Sq, which will have capacity to handle all city, regional and long-distance buses/ coaches and accommodate future expansion to meet the increase role for bus transport. It will include space for the various rapid transit systems envisaged in the LDP and be able to operate during 'event' days
    ** to meet the legal obligations of air quality re. the AQMA (Westgate St/St Marys St) by severely limiting new developments in the Central Square area to exclude non-essential vehicle access and parking, except where (more than) equivalent reductions in vehicle parking places and usage of Westgate St are also secured.
    Air Quality. In relation to the third clause to be added on air pollution, I would point out
    a) that the LTP and LDP lack policy on Air Pollution,
    b) that the AQMA issue had been raised in relation to the Central Square development but suppressed by the Council (and the developers’ masterplan),
    c) the recent Supreme Court decision that public authorities have a duty to implement an ‘action plan’ to meet the pollution limits transgressed in the AQMA and
    d) Cardiff Council has no viable action plan or intent to draw one up.
    Without a general policy on air pollution or AQMA-related policy as this one, the Council has no planning policies to implement its duty.
    ** two court cases against the Government have been prompted by a failure to meet EU nitrogen dioxide limit values. The first case, brought by Client Earth, led to a Supreme Court ruling in 2013 that the UK was in breach of its obligations under Directive. The Supreme Court referred the case to the European Court of Justice. The ECJ ruled on 19 November 2014 that the UK Government should have prepared plans to achieve compliance with limit values by January 2015. The Environmental Audit Committee’s new report Action on air quality (8 Dec. 2014) said New schools, hospitals and care homes must not be built next to air pollution hotspots to help reduce the tens of thousands of deaths currently being caused by nitrogen dioxide (NO2) and particulate pollution (PM 2.5 & PM 10) every year in our cities. The EAC seek new planning laws; pending the Welsh Government issuing new laws, the LDP should come up with a policy on Air Pollution that pays heed to their information. http://www.publications.parliament.uk/pa/cm201415/cmselect/cmenvaud/212/212.pdf
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    Hearing Session 14: Transport Matters
    The Regional Transport Hub’ (T4) is not only regional but a Welsh-national strategic transport interchange. On either account, leaving it vague in the LDP’s half sentence in clause j of objectives 1 (economic needs) "improving the city’s key transport hub... " is quite unsound. It would make the claims to a “world class integrated transport facility” just empty talk, a pretence to cover up the Council’s choice of commercial development of the Square above proper provisions for metro/bus rapid transit, city buses, regional and national rail and coach services. To conform with national policy, let the inspector insert specific clauses under objective 3: [To deliver economic and social needs in a co-ordinated way ….].
    ** to promote public transport as a means to achieve environmental objectives, to assist in relieving congestion and to encourage social inclusion
    ** to build an integrated transport interchange including a new bus station on Central Square, which will have capacity to handle all city, regional and long-distance buses/ coaches and accommodate future expansion to meet the increase role for bus transport. It will include space for the alternative rapid transit/metro systems and be able to operate during 'event' days.
    This should include or refer to a plan (as in the SDG report) showing the rapid transit alternatives as they pass through the interchange, as well as bus-routing and cycle/pedestrian routes.
    10. Does the Plan provide sufficient clarity and detail of the proposed Regional Transport Hub? No; the current specific proposals prevent options and undermine the basic purpose. The Steer Davies Gleeve report(SDG) used as basis for Central Sq plans is no more than an Appendix agreed by Cabinet prior to going for ‘Scrutiny’. Its proposing “a second location for a coach station in Cardiff be explored as part of a wider movement strategy” is contrary to LDP policy and has not been consulted on and adopted. It pays no regard to the Cardiff-Region metro study (cardiff-metro-update-report August 2014 is WG endorsed in the draft National Transport Plan) that requires “truly multi-modal transport interchanges, which include provision for active travel, at key locations. Cardiff Central Station, at the heart of the Central Cardiff Enterprise Zone, will be an early priority.” The LDP needs to define the functions of the Regional Transport Hub. The Cabinet-endorsed SDG report argues for a “world class integrated transport facility” and “a defining community feature instilling a sense of pride in users and the wider community”. Ticketing facilities, waiting areas, retail and catering specified; also design with legible spaces, direct convenient routes and visibility; adequate access points; efficient operations, spatial capacity for all station functions, appropriate space for all vehicles (including layover) and passengers. Usable, active and secure facilities for day and night use. well integrated with the surrounding urban context. Amenities need to relate to the type and frequency of services (eg. bus or coach) customers and dwell characteristics. They should also meet the changing need and use of bus services such as smart ticketing and quality information. The bus station needs to face onto Central Square and integrate with movements across it, not be dominated and conce4aled by the proposed office tower blocks of the Masterplan. SDG state the obvious – need for spatial capacity to meet predicted future demand, but then assumes figures that fail to do it (increase in buses by only 15%). In view of the Cabinet/SDG’s failure of this elementary planning principle, the LDP should specify assessing capacity for buses that could take advantage of the new bus station siting - with improved access/egress which allows it to include the BayBus, Airport coach T99 and city using St Mary’s Street. The LDP needs to specify road design to enable easy efficient bus access/egress to Bus Station, priority over other traffic, including running the metro-tram and BayBus etc. via Saunders Road.
    The LDP should specify the need to operate the Bus Station continuously from present, not close it down for 2 years or more to prioritise a development (BBC) that’s not part of the declared purposes of Central Sq (integrated transport objective) or the Enterprise Zone(prof & financial business services). With the failure of the LTP to state the case against closing the Bus Station, the LDP should do this and specify improving operations of our neglected station to handle further buses until the new bus station is ready. The LDP should also specify need to operate both metro-trams and buses during road closures on event days and Fri/Sat evenings. Saunders Road running is essential to avoid the regular closure of lower St Mary’s Street during Friday/Sat. evenings (an issue ignored by SDG). It is also essential in some options for routing the metro-tram ignored by SDG. SDG’s Fig. 2.13 indicates metro routing into a platform on the southern side of Central Station (south of Platforms 6/7). As Mr Davidson stated, the different electric power requirements will not allow a traintram to cross the main line, as required to serve NW Cardiff. Instead, an option needs to be retained to join the main line on the north of the Station, passing along Saunders Road or a viaduct over it. The metro train-tram needs space for high-quality waiting facilities and ‘station’ within the interchange. I showed examples from Manchester’s metrolink with its train-style platforms and ticket machines etc. The cardiff-metro-update-report-august-2014 “detailed investigation of a variety of possible Metro interventions” The LDP needs to state that option must be kept open, pending further decision. Legal limit on air pollution in St Marys Street/Westgate St AQMA. The assessment disregards the increased air pollution from traffic to and from the transport interchange, and disregards the exposure of people bus-users; the only receptors are said to be residents, yet air pollution law requires regard to numbers of people exposed for significant periods of time. Siting bus waiting there is incompatible with the unlawful levels of NO2. An Action Plan could include measures that affect the operation of the Regional hub eg. #limiting traffic, # introduce electric or hybrid buses # limiting taxis and/or requiring low emission taxis. It could also affect the and the development of the ‘strategic site’ in eg. tying any car parking in Central Sq to closure of car parking spaces. In the absence of a general policy on air pollution (as eg. in the Cycling Campaign’s case),the LDP should specify in regard to the Westgate/St Mary’s AQMA that the Central Sq development should be at least ‘air quality neutral’ and not lead to further deterioration of existing poor air quality (a policy in London). Because of the transportation importance, the LDP should specify that developments in Central Sq be limited to ones related to its functions for # prof & financial business services, #serving stadium crowds and # transport interchange, including facilities and passenger amenities ( as SDG). This would reject AECOM’s “wider regeneration vision … likely to include a number of land uses including retail, private residential apartments, student accommodation, a hotel and further office floorspace”. Taxis are part of integrated transport but given too high priority by Cardiff Council, in over-issuing licenses and not enforcing on-street waiting restrictions. Their proposal to displace taxis from the Station into Wood Street is wrong; buses and coaches need all the priority there, unless a study shows otherwise.




    Wednesday, 11 March 2015

    Cardiff labour council face £800,000 fines for lousy recycling

    The Welsh Government  have indicated that Cardiff council are likely to  face fines of c.£800,000 for poor recycling performance in 2013-14 Cardiff Labour council have written to the minister to make excuses for their failure to meet recycling targets. Cardiff labour council have managed to reduce recycling in Cardiff,  they are an outstanding failure.   They have failed because they refused  to introduce recycling kerbside sorting leading to an  ongoing shortfall in income levels from  Recycling.  Sales of sorted materials are getting low prices due to poor quality, some are being stockpiled awaiting market improvement (unlikely to happen). We pointed this out  this time last year but the council refused to listen.  The Lamby Way MRF has underperformed, contracting out large quantities - sorting 400 tonnes rather than the 600 tonnes per week expected.
    The forecast was for 56-58% recycling in 2012-13, but they managed a bare 52% that amounted to an extra £650 000 in landfill tax alone. Now the latest figures are just 49%. 


    Closing Waungron Road recycling centre is also a huge mistake, will lead to even less recycling. Recently  99.6% Fairwater  people voted to demand its re –opening but still Councillors Mitchell and Derbyshire refuse to listen. They need to be recycled before Cardiff is bankrupted. 

    Recycling in Wales The LA with the highest rate of rate of reuse, recycling and composting in the 12 months to the end of September 2014 was once again Denbighshire, which came in at 66 per cent. This marks a six per cent increase on the area’s annual rate recorded in September 2013. Monmouthshire County Council (65 per cent) recorded the second best percentage, with Pembrokeshire County Council (64 per cent) in third. Cardiff is second worst. 

    Bias one sided reporting - Smaller bins and bespoke bin bags - the ways Wales' biggest council hopes to avoid £800k fine