Friday, 22 May 2015

NRW stops Cardiff Council who have no permit for their incinerator ash operations

Scam over Viridor’s Incinerator Ash is ending
Cardiff Council’s efforts to make money from Viridor’s incinerator ash appear at an end.
The metal screening equipment was yesterday taken down off the tip and is now parked up next to the buildings on the tip.   Ready for press photographs if you hurry.

Viridor was forced to install metal separating equipment at its incinerator from end April.  Temporary plant has been brought in, operating within the building, so without the dust-blow at Lamby Way.  They are installing modern magnetic and eddy current separators for long-term use.
Cardiff Council was forced to submit a “Risk Assessment” of its metal screening operations on Lamby Way tip.  The NRW has not accepted it, as “not provide sufficient detail in their assessment of potential impacts of dust generation”. 
CATI points out that it’s a poor, amateurish document that in no way measures up to the NRW’s guidance, or to the similar operations in England by Raymond Brown Ltd (Andover) who call themselves ‘specialist’ in incinerator ash processing.
CATI has pressed NRW (Natural Resources Wales) to take action against Cardiff; they were found to have no permit for their incinerator ash operations.  Eluned Parrott has likewise pressed for action to stop the toxic dust from incinerator ash spreading to residential areas of Rhymney/Rumney and Tremorfa.
The NRW has been slow in taking action, but at last !

UPDATE on Ash Tip operations stopped
The ash screening equipment and conveyors have now been covered over, to protect from Press photographers. 
Cardiff Council's JCBs and dumper trucks are now spreading the mounds of ash over areas of the site (claiming for 'engineering' or 're-profiling' the site), raising clouds of dust blowing in today's strong winds.  This incinerator dust is toxic, but the Council (with collusion of the NRW) ignore the harm to health and environment, pretending it does not get off site.

Splott incinerator campaigners hit out at Cardiff council for 'breaching duty of care' over Lamby Way recycling site​

Monday, 18 May 2015

Public acceptability of Cardiff Bus Station proposals

Recent letters to the Echo have questioned scrapping Cardiff’s bus station on a promise of another, on an over-small site, years in the future.  Your columnist David James criticised putting “transport infrastructure second to the demands of developers – as Cardiff seems to be doing” (30 April, Echo p.14).

The 29th April planning decision on Central Square does not settle the issue, for Councils have in law to test ‘public acceptability’ of major transport infrastructure.
This Council ‘consulted’ the public just on whether the bus station should be in front or behind the rail station. Then came ‘stakeholder’ discussion of problems and opportunities.  Next - says the core Welsh document on transport planning (WelTAG) – public acceptability of the proposal will be a key test. 

Are the present Council leaders really intending to omit public consultation and acceptability?

The previous Council leadership (Lib-Dem/Plaid coalition) did consult in 2011 on a similar siting of a new bus station.  The Welsh Government said then (2012) the Council needed to   “revisit the WelTAG work, including appropriate engagement with the public”.  The current proposals are further changed, in particular to exclude bus access via Saunders Road (by the Great Western pub).  They block any operating of the bus station during match-day closures. 

The developer-plans for Central Square do not decide over transport planning.  The council owns the land and must use it in the best interests of Cardiff, bearing in mind environmental and transport issues.  Let the Council now lay out their plans clearly, show how they meet (or fail) the principles for a Bus Station and truly multi-modal transport hub, and subject them to the public acceptability test.

Wednesday, 13 May 2015

Broke Cardiff Council hires Blair adviser

Not so long, about 2 years, since Cardiff labour faced criticism for proposing to recruit £80k advisor for council leader Heather Joyce which was described as obscene.  

Absolutely broke Cardiff council still faces “many significant challenges” in raising school standards, inspectors have warned. So Cardiff’s director of education Nick Batchelar says Cardiff Labour Council enlisted former UK Government adviser Robert Hill to act as a “critical friend” in the drive to raise standards in the city. Mr Hill, who worked under Prime Minister Tony Blair, will join the authority in June and is expected to stay for at least a year.  Paul Orders Cardiff Council Chief Executive suggests the regional education consortium, not Cardiff Council, will pay Robert Hill. Councillors are unhappy the role wasn't advertised. His salary hasn't been disclosed.
Find him on twitter Robert Hill @Robt_Hill
He seems keen on academies and how to improve them by creating Academy chains We dont have academies in Wales. He likes competition and partnerships between schools - bigger the better man.
Mr Hill said there is a “strong case on both educational and cost-effectiveness grounds” for the majority, and potentially all, of schools in Wales to be part of a formal federation or hard cluster with shared governance arrangements.
If approved, the federation or cluster could be primary-to-primary or secondary-to-secondary in structure, to be led by an overarching executive headteacher. Typically, federated schools retain their own identities but share services in order to enhance opportunities for their pupils. Currently, school governing bodies have the final say on federation but Mr Hill suggests the Welsh Government take a stronger role in setting out “clear direction of travel” for schools to work together more formally.
Robert Hill Tony Blair's Political Secretary. Former health adviser to Tony Blair at No.10, became Political Secretary to Blair in 2001. Used to work for the Audit Commission and Capita. He was a press officer for Tony Blair before the 1997 election

Between 1997-2001 Robert Hill worked in the No 10 Policy Unit as the Prime Minister’s adviser on health issues. Charles Clarke became Education Secretary in October 2002 Robert Hill joined him as his special adviser then to the Home Office to advise on police reform, immigration and criminal justice issues until May 2005. 

Thursday, 7 May 2015

Carl Sargeant - Cardiff Bus Station not more than local importance

On election day Carwyn Jones feigns concern about the bus station when he should know that his Welsh Government dismissed it and refused to call it in because it does not appear to raise transportation issues of more than local importance and therefore call in is not supported 

 Carwyn Jones warns Cardiff not to compromise public transport at Central  rather late the BBC and offices have been given planning permission already He refused to call it in as it isn't important enough - here is the letter signed by the DECISIONS BRANCH for the minister for natural resources.  

Minster for natural resources Carl Sargeant 

WG NO CALLIN letter 1 

WG NO CALLIN letter 2

WG NO CALLIN letter 3 

WG NO CALLIN letter 4

WG NO CALLIN letter 5 

Tuesday, 5 May 2015

20 things you need to know about Cardiff’s new Bus Station

Cardiff Council PR man Ian Lloyd Davies drums up 20 things you need to know about Cardiff's new Bus Station – Fact v Fiction  01 May 2015 for Cllr Ramesh Patel - with biased Answers and some vital questions avoided.   

We bring you our Alternative 20 things you need to know about Cardiff’s new Bus Station

Here are alternatives – attempting to be open and honest –
using the documents posted on their website.
Question 1: Is Cardiff to get a new bus station?                                            A.  Maybe not. Cardiff council hasn’t £10-20 million for building costs. The site they allocated is small and huge office buildings planned above it may be delayed (picture at end).  The Council doesn’t own the site for the adjacent waiting hall, information office, food kiosks and loos, nor have funds to buy it.

Q2 How will buses access a Bus Station on the Marland House/NCP Carpark site
A.  From Wood Street, nearly opposite Westgate Street. This means awkward dog-legs for outgoing buses via Havelock Street into Westgate St, crossing buses queuing to enter the bus station. The consultants Aecom considered highway changes to meet the worsened bus and traffic congestion, including stopping general traffic on lower Westgate St, but were not sure they could work.

Q3 How will the pedestrian safety issues be addressed, with turning buses crossing the main pedestrian routes? 
A.  The consultants’ Buro Happold judgment “represent a safety risk to pedestrians” was suppressed by the officers’ report.  New traffic lights coordinated with those at Havelock Street will delay buses and limit numbers though the Bus Station.

Q4 What about claims that air pollution in the confined Bus Station will be high
A. Consultants considered the illegal-high levels of pollution in Westgate and St Marys Streets, finding only small worsening.  They omitted pollution levels in a new bus station and the council officers decided to ignore them too.

Q5 Will buses currently stopping on Wood St and lower St Marys Street use the Bus Station and integrated transport hub?
A.  No.  Planning was only to cover the 41% of city buses that use the current Bus Station

Q6 Will the Bus Stops and shelters on Wood St be replaced?
A.  No.  Inward buses will have only a set-down stop with no shelter, outward (westward) buses will have stops and shelters in Tudor St.

Q 7  I’ve read that the bus station won’t be ‘world class’ and not big enough for the future.  Is this correct?
A.  Yes. The Council has dropped its ‘world-class’ claim.  They would make do with 14 stands by cutting bus dwell-times to about 6 minutes (compared with present 10-12 minutes from 22 stands).  Coaches could not be allowed 20-30 minutes for loading and for driver comfort-breaks as present. Future Rapid-Transit services would likewise not be allowed time-tabled waits.  There’s no space for predicted increases in bus and coach services. There’s no space for Bendibuses nor for layover bays, which Cardiff Bus wanted.

Q8 What about accommodating the national coach services?
A.  The consultants said to provide a Coach station ‘elsewhere’. The Council did not report this and have done nothing, apparently hoping coaches would stay in the temporary Sophia Gardens coach park.

Q9  Will the new Bus Station function on Stadium-event days?
A. No.  Buses are not to use the Saunders Road access, by the Great Western Hotel, as in previous plans. The Council ignored its consultants Buro Happold who wrote “careful consideration must be given to how the bus station can remain operational on an event day”.

Q10 Why can buses not use the simpler Saunders Rd access, avoiding congestion and conflict with pedestrians?
A.  Because the Council reserves this access for a new 350-space car park for businesses on the Square

Q11 Why give the BBC centre 217 parking spaces in the new Saunders Rd carpark?
A.   The 83 parking spaces in the BBC’s basement are too few for the workers there. Cardiff Council thinks they need carparking within a 50-metres walk; in comparison, bus-users are supposed to walk up to 400 metres to their buses under the 1988 guidelines that Cardiff planners use.

Q12  What about concerns that the BBC will be a focus for demonstrations and a target for bomb attacks?
A.  The police Wales Extremism & Counter Terrorism Unit had many concerns, saying the Rail Station would have to be closed on occasions. The developers have been asked to take into account made the many recommendations on security enhancements

Q13 Are the BBC’s plans for open public access compatible with security
A.  No. The public exhibition space and passage through to Wood Street are vulnerable to persons carrying explosives.  Bollards would be provided all round the building against bomb-carrying vehicles, but retail units adjacent and on the ground-floor remain vulnerable. 

Q14  Who will pay for the special security measures
A.  The police report warns of capital and revenue costs. The developers will meet initial capital costs for bollards, including rising bollards and their supervision; the public purse pays for on-going policing and maintenance, while the public suffers from public transport disruptions.

Q15  What benefits does the BBC get from the Central Square siting?
A.  Like other businesses in the Central Enterprise Zone, they pay reduced rates and get special capital allowances.  These tax-benefits are to attract new jobs in Business and Financial Services, yet the jobs are simply transferred within Cardiff and are not in the BFS  sector.  The criteria set by WG officials still allow these benefits to Welsh companies (‘crony capitalism’).

Q16 Are the developers making the normal S.106 payments towards transport and other communal infrastructure
A.  No.  Nothing for transport infrastructure outside the detailed planning site, nothing towards a new Bus Station, nothing towards a cycling hub and bus/rail station cycle-parking. Cardiff Council did not require the BBC developers to pay for sites for the new bus station and transport interchange.

Q17  Why was the replacement Bus Station not included in the Central Square plans along with the BBC Centre?
A.  Cardiff Council wants the freedom to cancel the new Bus Station if they can’t get new grants for it, or for reasons of practicality or because they prefer more car parking.

Q18  It’s said the new bus station won’t be integrated with the new Metro system if one is built in the future. Is this true?
A.  Yes. The on-street Metro-tram option is routed along lower St Mary’s Street and Wood Streets with no space allocated for a Metro-station. If a station with raised platforms could be squeezed into Wood Street, at the Marland St junction, the planned hotel on the corner site would prevent direct access into the Bus Station.  The plans also block the alternative tram route via Saunders Road into a possible Metro station alongside the Bus Station.

Q 19 Why close the bus station on 1st Aug., over 2 years before a new one will be ready?
A.  The Council is disregarding the Welsh Government policy Where transport improvements will be needed to enable the proposal to go ahead, these should normally be provided first” because their priority is to meet the wishes of the developers and the BBC.

Q 20 Why no consultation with the Cardiff public on the details of these highly important plans
A.  The Council held the minimal consultation for small planning applications, but not the special exhibitions and consultations normal for large applications of wider public interest. The Council decided that their consultants AECOM would “engage with a range of key stakeholders” but not the public. The over 150 e-documents with this application are hardly accessible to the general public, with no explanatory material.  The local (Cathays) councillors did not help.

Spot the “new transport hub, linked to Cardiff Central Railway Station, on the eastside of Central Square”. The Bus Station site is half-hidden under 500,000 sq ft of new commercial developments. The bottom building with canopy is supposed to be a transport interchange.  A 350-space car park is planned too, with access via Saunders Road (off picture, bottom left), under or over the Bus Station.
Phase 3 of Central Square development
Spot the Cardiff Bus Station site half-hidden under 500,000 sq ft
 of new commercial developments. The bottom building with 
canopy is supposed to be a transport interchange. A 350-space 
car park is planned too, with access via Saunders Road 
(off picture, bottom left), under or over the Bus Station.

A Cardiff Bus users campaign join us on facebook here  - This is not related in any way to the Bus Users UK or their branch office Bus Users Cymru who support the labour party plans.   

Utrecht to build world’s biggest bike park – for 12,500 bikes Business April 27, 2014    Building group BAM has been contracted by Utrecht city council to start building what it claims will be the world’s biggest bike park – a three storey construction with space for 12,500 bicycles. The initial contract, to build the first phase of the bike park, is worth €8m. The total cost of the project is €48m, BAM says. The underground bike park will form part of the redevelopment of the area around Utrecht’s central station and will be completed by 2018.

More or less the same size as Cardiff, the Dutch regional capital Utrecht knows a thing or two that Cardiff might have learnt before it gave consent for the BBC to land-lock the site of the current bus station. Not only will Cardiff have to wait many years for a new bus station, it will be without one. The city is promised a ‘state of the art’ transport interchange. It had better note that Utretch already has one. 

Utrecht to build world’s biggest bike park – for 12,500 bikes 

Friday, 1 May 2015

Goodbye bus station Hello crony capitalism - congestion - Air pollution - Hell for bus users

'Don't be dazzled by a fancy building - cities are nothing without transport' At least one journalist can see our point of view. Cardiff labour and the Welsh government are still living in a bygone petrol head era. Instead of a modern approach to urban planning putting public transport and cycling first here we have build huge office buildings for the BBC with numerous vehicles and parking requirements to be built on the current bus station site right bang in front of the railway station. Unless we stop driving cars, all other sustainable transport plans are pointless 

In reply to my objections Cardiff planning officers reply to my objections to BBC and no bus station they have the temerity to expose their ignorance by stating 
"8.87 There is no requirement on Cardiff Council to provide a new bus station. Whilst local authorities have the powers to provide bus stations they do not have a duty to do so. That being said it remains the stated aim of the Council to provide a new facility"

Cardiff Central Sqaure in front of the railway station just happens to be in the recently created Enterprise zone which is why the BBC is getting off paying a huge chunk of 106 money and money off business rates and an enhanced capital allowance ..but does the BBC qualify as it is actually downsizing to the new central square office with fewer jobs not more? 
  • Business Rates Scheme - help for new and growing businesses in Enterprise Zones to ease the burden of business rates
  • Enhanced Capital Allowance - assistance for businesses in designated Enterprise Zones to claim a 100% first year allowance for the capital cost of investment in plant and equipment made before 31 March 2017
What happened to the promised "A new centre transport interchange including a new city/bay metro transport system, linking together the various business hubs of Cardiff;" Mr John Antoniazzi ChairmanCentral Cardiff Enterprise Zone

Welsh economist Gerald Holtham says Wales’ enterprise zones “appear designed more to meet political objectives than out of any industrial or commercial logic”
left to right Jon Antoniazzi, Edwina Hart and John
 Smart at Capital Quarter June 2014 
“If doing too much is one danger in a small country, another is crony capitalism,” Mr Holtham says. “That does not necessarily imply anything corrupt or illegal. Yet big businesses and the prestige of their managers or proprietors can often have a disproportionate influence in a small country on politicians with no business experience. I think this answers the questions below.
Jan 2015 Edwina Hart claims 465 jobs have been created in the Central Cardiff Enterprise Zone  reluctantly admitted. Plaid economy spokesman Rhun ap Iorwerth said the figures showed some of the zones are doing better than others. He said that the Cardiff zone saw 465 jobs safeguarded or created at a cost of £22.9m – “a cost per job of some £44,000”.
And what has Ramesh Patel Cardiff Cabinet Member for Strategic Planning, Transport & Highways 
Nothing on why the 'new' bus station is left until after the BBC planning permission. Ramesh Patel reponse   is a joke  "To clarify, all proposed designs for the new bus station include a high-quality passenger waiting concourse.  ....The planning application for the bus station (which we haven't seen yet) is not ‘outline only’, but a detailed planning application, delivering a facility which is world class and fit for purpose befitting a growing capital city. It includes an integrated transport hub, which will include significantly improved – among the best in the UK – cycling facilities"  Perhaps someone could explain what an integrated transport hub is? Cycling facilities otlined so far in the recent planning application  have been slammed by the Cardiff cycling campaign experts and fall way short of world class!   
Why not provide a new Bus Station/Interchange on the Marland House site first? 
Welsh Government policy is not worth the paper it is written on. 
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.
Failure to comply with policy for a Regional Transport Interchange that the Welsh Government boasts of in their brochure to attract business to the 'enterprise zone'  
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. 
Rightacres the developers ridiculous claim ... 
  • Minimise negative environmental impacts and enhance the local area
Can you even spot the bus station? Not sustainable Not 'active travel' 

Note that Bus Users Cymru supported these plans i.e. Margaret Everson at Bus Users awarded an MBE in Queen’s 2013 Birthday Honours nothing to do with the independent Group Cardiff Bus Users

For your information...

Latest propaganda from Cardiff Bus 20 things you need to know about CARDIFF’S NEW BUS STATION – Fact v Fiction  Yes will be too late to object if too small...cart before the horse 

Reply to Ramesh Patel from Max Wallis 

Unfortunately you do not address as I did, the outline planning application for the Bus Station given in the documents before the Planning Committee.  You've been impressed by detailed plans not in the public domain, but the Committee and public have to deal with those on file.

Those say that public coach services are to be provided "elsewhere", not in the future Bus Station.  They say westbound bus/coach stops in Wood St will disappear, space being allowed only for the 41% city services using the current bus station, plus 15% for all future increases including your rapid transit buses.

The plans do not provide any site or funds towards your Hub's cycling facilities.  Rather, they delete the current Station parking stands for ones scattered in the development, unlike comparable stations with 200-400 parking places.  The plans provide for 'dedicated' cycleways along Wood Street, yet these would end abruptly at bus-stop bays and would be scrapped if Metro-trams come.

Road and pedestrian accesses to the Bus Station on Wood St are to be determined under this outline/hybrid planning application.  Even the consultants (Aecom) express uncertainty that the proposed bus access could work at the congested Westgate St/St Marys Street corners, even with their suggested traffic changes including stopping up Westgate St to general traffic. It certainly fails the Council's requirement to minimise conflict with main pedestrian routes.

The outline application does not remove the car/taxi parking accessed via Saunders Road, though removal is part of Bus Station option 2 (to give bus access for functioning on event day closures); on the contrary, it means permission for a new 350-space car-park there.  That would cost £millions to cancel, on top of the £9 million to buy out the NCP carpark.

There's no requirement on the developer to secure the key site for the "high quality passenger waiting concourse" you promise, to make up for all the public land given them.  Any costs of compulsory purchase would fall on the public purse. Astonishingly, says the Civic Society, the proposed S.106 agreement includes "not a penny towards transport infrastructure".
The plans provide for one option for Metro-trams, to run along Wood St. but without space for a station. Rather than keep options open, the plans stop their routing along Saunders Rd, the one option that allows a metro-station in the integrated transport interchange.

So I would hope that you will now recognise the crucial deficiencies in the current plans, and support a call-in by the Welsh government.  This would enable scrutiny of the current plans, against the WG/Metro truly multi-modal Regional Transport Interchange and your 'Integrated Transport Hub' concept with no coach services, under half the city buses and shut down on event-days.

With Regards,
  Max Wallis  
  Cardiff Cycling campaign and Bus-Users group

Capita chosen to design Cardiff's £27m Eastern Bay Link Road 

Tuesday, 28 April 2015

Security and Public Demonstrations risks to Transport Facilities

Cardiff failure of officer to include in documents and to properly report the policing problems, limitations and costs of putting the BBC Centre there.  Phil Bale never thought of policing implications and the officers concealed them. 

Cc: Dowdall, Lawrence
Subject: Central Sq planning application 14/02405/MJR
Security and Public Demonstrations risks to Transport Facilities

At my request, the Case Officer late on Monday e-mailed me a copy of the South Wales Police response of 23 January 2015.

The following passage in the Planning Report does not adequately represent the risks stated by the Police authority, being not only cursory, but also failing to recognise potential disruption of functioning of the rail/bus stations and ignoring the capital and revenue costs.
8.95  The design of the building and the public realm have taken into account the high profile nature of the building and the location. Comments from SWP have been forwarded to the agent. Details to discharge the public realm condition will include appropriate security measures. The security requirements for the future bus station will form part of the subsequent bus station application.

The Masterplan said WECTU (Wales Extremism & Counter Terrorism Unit) will be reviewing the scheme in conjunction with the design team to ensure the structural resilience of buildings and public space to potential threat.

The South Wales Police 'comments', 23 Jan. 2015 (presumed on behalf of the WECTU) are very extensive.  Responses from the agents/applicants need to be reported.  Points on 'vehicle mitigation', secure accesses and numerous bollards (rising and not) have street design implications, which may affect the images and diagrams presented.  I find no update in the March 2015 deposit documents.  There is no evidence for the statement in 8.95 that "The design of the building and the public realm have taken into account the high profile nature of the building and the location" fully and properly, in the light of the Security response.

The SWP response contains:
  • The siting of the high profile BBC Centre mid-city next to the main railway station "would significantly Increase the attractiveness of the area to extremists and possible demonstrations (which)  would not only impact on the BBC but also on the transport hub and local businesses.”
  • “a major bomb alert in the building (may require to) evacuate adjacent premises such as the railway station causing major disruption to the network”.
  • Crowds during events in the Millennium Stadium and also at seasonal times such as Christmas “could prove problematic for identification and control purposes”.
  • “There would be ‘on-cost’ implications on both capital and revenue regarding control of the site.”
It’s a serious failure (breaching EIA REgs.) not to post up this SW Police report as part of the documentary evidence - enabling consultees to respond - and in not reporting its findings/cautions.  
  In particular, the rail station's owner and operator has a direct interest.  The implied costs to them would legitimately fall on the developer, as costs likewise to the operators of the new Bus Station and Transport Interchange.   Responsibility for the " ‘on-cost’ implications on both capital and revenue regarding control of the site​" (apparently the whole Central Sq area) needs to be defined and the costs attributed.  Shouldn't the special policing and other costs be attributed to the developer?

Request to WG for Call-In of Cardiff development 14/02405/MJR Central Square, due 29th April

to: Carl Sargeant, 
Minister for Housing and Regeneration.

Request to WG for Call-In of Cardiff development 14/02405/MJR Central Square, due 29th April
Scheduled for a special planning cttee of 29 April, officers recommend approval
The hybrid application comprises outline permission for development of the whole of the Square in front of the Rail Station plus detailed permission for buildings, public realm areas, highways (Wood St) and accesses to a future Bus Station, covering most of the present Square and part of the site of a building to be demolished.

We recognise the conditions you as Minister require to justify a call-in:
• in conflict with national planning policies or
• could have wide effects beyond their immediate locality or
• may give rise to substantial controversy beyond the immediate locality.
We maintain that the application meets all three conditions:
It conflicts with your policies for a Regional Transport Interchange and Active-Travel; it impacts on bus-users throughout Cardiff and the wider city-region; it would raise controversy through the whole region if people knew Cardiff intends to contract away the public land needed for a regional bus station and make the Council leader’s claim of a ‘world class’ bus station undeliverable.
Cardiff Bus-Users were represented at the recent Cardiff LDP Inquiry, submitting detailed evidence and taking part in the discussions.  Our evidence included the inadequacy of plans for the new central Cardiff Bus Station.  The Council gave no evidence in reply.  Their responses to the Inspector’s questions were due by end of April, so could have been covered in the Planning Report, but are not.
We first point out the high importance of the development site, our current Bus Station:
The site is important in Cardiff central enterprise zone - a WG employment initiative. Yet the proposed uses do not meet the purposes (Financial and Professional Services) for which this enterprise zone is designated. Nor does it meet Planning Policy Wales 8.6.2 that a site highly accessible to non-car modes is to be used for travel intensive uses.
The site is needed for a Regional Transport Interchange - in studies for a Metro in Cardiff city-region (A new rapid transit route from Cardiff Bay to Pontyclun/Beddau via City Centre).  The Council and Inspector at the LDP Inquiry (Jan-Feb. 2015) called it a Regional Transport Hub and considered evidence submitted that Central Square is the accepted site. This marks the development clearly as ‘more than local significance’. 
The WG Minister (5th Dec. 2014 NAW scrutiny session) endorsed the Aug. 2014 Metro update (Mark Barry report) that stated Cardiff Central Station, as a key location at the heart of the Central Cardiff Enterprise Zone, will be an early priority truly multi-modal transport interchange.
The Minister gave it regional and national importance: “the Metro will be the catalyst for transforming the economic prospects of the region and Wales”
We make some detailed points re. the present plans:
1.  the space allocated for the bus station is wholly inadequate; the plans fail to accommodate public coach services, and fail to accommodate the substantially increased city-region buses proposed within the decade. 

2. This exclusion of coaches breaches the WG/Metro spec for truly multi-modal integration and Cardiff’s  LTP of Jan. 2015 saying the Council “will continue to facilitate the high profile use of Cardiff Bus Station by Traws Cymru services”

3.  the Bus Station could not operate under road closures for Stadium events; a future Metro might operate during Stadium events (except for a short period), but this is not considered

4.  the Cardiff public have not been consulted over the reduced space and poor accesses for a Bus Station, but falsely informed that it will be “world class” with a “Concourse” of passenger facilities.  Both are untrue – the restricted plans would be highly controversial (if known) but the Council has breached the engagement and involvement principle of Planning Policy Wales and the Public Participation Directive.

5. The plans propose to remove from Wood Street the Bus Stops and shelters for west-Cardiff and Vale destinations without allocating alternative sites.  The Council may try and displace them into lower St Marys Street (displacing loading vehicles and coaches) or into Tudor Street (as on ‘event’ days) with significant walking from Central Sq and quite contrary to the integrated interchange concept.  We point out the council wrongly uses 400metres as a distance that pedestrians are expected to walk to access buses.

6. there is no allowance for promised “Rapid Transit Buses” to serve new Cardiff suburbs and the wider city-region.  Nor is there allowance for the Metro-tram, that might be introduced as the rapid transit mode to NW Cardiff.

7. the proposal may prevent the option of a Metro-tram station, with running along Wood street as depicted:
·         The narrowing of Wood Street to single-lane highway prevents a Metro-tram inclusion with other planned uses (busstops/layby, designated cycleways, wide footways, BBC TV, Bus Station and Hotel accesses).  
·         No space is allocated for a Metro-station on Wood Street or elsewhere, to be part of the integrated hub.
8.  A metro route entering Central Square from Saunders Rd has design and operational advantages for integrating with rail and bus (free from congested traffic and relatively free of conflict with pedestrian bus and rail users), but is not considered and would be blocked by the proposals.

9. the proposed access via Saunders Road for a new car-park prevents use of this route for metro-tram access into Central Square and the transport interchange; it also blocks the Bus Station option 2, the one option that facilitates operating the Bus Station during street closures for Stadium events.

10. The proposal for a new 350-space carpark accessed via Saunders Rd flouts PPW  8.4 Managing traffic and parking in central areas: “refuse planning permission for public and private car parks which do not meet the strategic aims”.

11. Buses are major sources of Nitrogen dioxide pollution, the reason for the central area being declared an AQMA on grounds of illegal levels of this gas.  The proposals worsen this, not so much in the extra traffic but more because of increased bus congestion and queuing. No proposals to mitigate this are included.

12. The proposed new Bus Station in a confined space between buildings is likely to suffer similarly high and illegal levels of the nitrogen dioxide pollutant. The Planning report and the applicant's documents do not consider this issue or ways of mitigation.  The council prefers to treat it as a design issue, yet it's material to the planning decision and could rule out siting any Bus Station in such a confined space.   

Please confirm that you will act promptly to stop the Council approving these plans and call in the planning application for further consideration.

Cardiff Bus-Users group