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.
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 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
- 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.
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.
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.
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;
The Well-being of Future Generations (Wales) Bill http://www.assembly.wales/laid%20documents/pri-ld9831%20-%20well-being%20of%20future%20generations%20%28wales%29%20bill/pri-ld9831-e.pdf
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