Tuesday, 28 February 2017

Objection to new 'bus station' that isn't a bus station

Cardiff & Vale Bus-User Group
Objection to the Central Interchange proposal 16/02731/MJR
The developers’ promise of a “world class” interchange – in exchange for the valuable land donated from the old bus station – is not provided in the present scheme with facilities sized only to the bus-station users.  The officers report ‘forgets’ to consider this, despite the Council Leader making the “world class interchange” claim on many occasions. 

Integrated transport is not provided in the present proposals, with no integration with rail information systems, no information on buses stopping on adjacent streets . The nearby bus-facilities for bendibuses (excluded by design) and others choosing not to divert via the tight bus-station, have to be considered as part of the interchange, so should get high quality upgrades.   These facilities and foot-ways to them have to be assessed for DDA compliance (under the Equalities Act).

Funding for high quality pedestrian routes to external bus stops, new shelters and information systems is owing from the valuable bus station site given to Rightacres, and can be secured by extra S.106 conditions.  Likewise, funding for a future Metro station-halt in Wood Street (excluded from the Interchange design) should be secured via a S.106 condition to fulfil the integrated transport promise.

The Central Square business and residential developments rely on extra use of Central Station rail services, yet the rail station is already overloaded.  The integrated transport interchange requires additional passenger facilities for rail as well as bus and coach transport.  The rail station/booking hall being constrained by the listed building status means that the new “interchange” needs to provide the bulk of the combined passenger facilities – waiting rooms, loos, café, travel information, hotel and car booking etc. 

 Further detail
1. Failure to provide requirements of the promised integrated interchange
Passenger facilities are too small and limited to bus station users only.
• needs to include loos, seating areas and refreshment facilities for bus passengers having to use stops in nearby streets
• needs to provide information on bus services in nearby streets and how to reach them; that includes staff advisors and porters
• needs to provide facilities for rail users, including an information board on rail services
• needs to provide information on public coach services and how to reach their stops external to the bus station.
• integrated tourist information and hotel booking should be guaranteed.  While the retail units could provide a location, tourist information should be an integral part of the development – so allocated a site with paying the high rents.
• Late night waiting facilities should be guaranteed, serving rail as well as coach passengers, with overnight staffing

2. Pollution limits on Buses.  We object  to restricting the number of buses using Westgate St/Wood St  to current numbers on the basis of their polluting emissions.  The Central Sq  development was permitted on the basis that
a)      A new bus station could be sited on the Marland Ho. site to take all then buses plus expected increase (said to be 15%).  Current numbers are lower than the base level, including all the coach services diverted elsewhere.
b)      traffic from the development would not significantly impact on bus and traffic flows
There are many diesel taxis, emitting excessive NO2, as well as buses.  Much of the buses’ emissions arises due to congestion caused by other vehicles, due to the waiting and stop/starting.  Diesel cars including those fitted with unlawful ‘cheat’ devices are also significant emitters of NO2
• traffic management to divert non-bus, non-essential traffic  would  relieve the buses from congestion, and keep down diesel-cars
• purchase and use of low-emission buses and low-emission taxis;  the developer should contribute a significant sum towards the new vehicles
• requirement on the BBC to introduce low-emission operational lorries and to incentivies all staff vehicles to be low emission.

3. The Bus Station’s 14 stands are too few to accommodate all bus services; the developer answered that the “Interchange” is to include stops in nearby streets (Lower St Marys, Custom House St, Wood St).  The design excludes bendibuses - the Baybus and the 17/18 service – which would be forced to use these stops. 
Information and signing systems must therefore include those buses
•  requires signs etc at those stops as well as to them. 
• Routes to-and-from with any crossings should be defined with recognisable paving. Disability compliance (Equalities Act) needs considering in these routes.
The Access Group was consulted on the design of the Interchange building only, not the links to it and to the dispersed bus stops.
• The Bus Stands at the dispersed stops need to be upgraded (funded by the developer) to permanent structures with adequate capacity and seating/information facilities comparable to those in the Interchange building.

4. Bus-route changes: it is unacceptable in procedural terms to force bus-route changes in areas outside the planning application site, without specific consultation on them.  This applies in particular to preventing buses northward on Penarth Rd.
4a. Unacceptable to prevent buses from Cardiff Bay using the Penarth Rd route to the centre.  The stop south of the railway bridge (Routes 2, 6) is essential for easy access to the rail station.
4b. Unacceptable to prevent buses from W and N-W Cardiff during event-day operation using Penarth Rd and then Canal St and Custom House St to turn back onto the Penarth Rd.
4c. Unacceptable to open Penarth Rd southbound to general traffic and clog-up the buses.  Cars from the BBC car-park could block this route just like cars from the Marriott Hotel carpark choke the buses eastward along Custom House St.

5. The 215 car-parking places for the BBC should not be provided in the Interchange building.  Like the Network Rail/Arrivatrains replacement parking, they could be provided south of the station (the Brains site is suggested; there are other sites within the 400m from the BBC building said to be acceptable walking distance).
• bad for Cardiff’s image to provide car-parking in a “world class” transport interchange
• petrol/diesel car movements generate pollution in a sensitive area (pollution levels outside the Great Western are predicted to worsen significantly),  important for pedestrian s.
• need to restrict the number and variety of vehicle movements on the key pedestrian route of Saunders Road and its junction with Penarth Road, as Network Rail argue
• existing congestion on Saunders Rd is significant from taxis, service traffic and the NCP car park, so that buses from the interchange are likely to be caught in future congestion (no study is presented to show otherwise).

6. We support Network Rail’s criticism (6.7) that a true ‘transport interchange’ requires clarity on the interrelationship between this Interchange and their rail station.   We agree with Network Rail that the development has to contribute funds for increasing station capacity, just as a developer has to contribute funds for adding necessary road capacity.

We support their request for financial contributions to cover the provision of Customer Information Systems within the station concourse area, for the provision of bus and coach journey information; also for additional passenger facilities at the rail station for the extra rail-users generated by the development’s business and residential components.

7. DropOff/PickUp places are unacceptable on Penarth Rd (under the bridge)
• no pavement under the Bridge, east side, no crossing from places south of the bridge
• long distance to bus-station, up-hill on restricted (crowded ) pavement on west side
• crossings of busy Saunders Rd bike and taxi lanes


8.  Key pedestrian route Saunders Rd. (1.31)  cf. Network Rail’s description in 6.7 as “popular and well-used pedestrian route linking Cardiff Central Station with the city centre”.
We support Network Rail’s concern  that the development will fail to create a safe and attractive pedestrian environment along Saunders Road given the range of vehicular movements.  They rightly say the quality of the public realm and the safety of pedestrians at these crossing points is critical.  We support their proposal for the Section 106 agreement to require the creation of a high quality public realm environment on the northern side of Saunders Road, to ensure that pedestrian safety and ease of movement is prioritised over vehicular flows.

9. We object to the failure to plan for event-day use of the Saunders Road route by buses.  Saying signals are not needed on non-event days because bus movements are few (1.31) is no excuse – signals have to be provided for event-days.

10. The Penarth Road footway is also key, linking the Bus Interchange to the business developments (Callaghan Sq and Dumballs Rd) including the new C&V College campus.   People pull wheeled luggage up it from the T9 coach and buses from Cardiff Bay (the Bendibuses will not be accommodated in the Interchange building)
This footway is substandard in width and often crowded.  Its crossing of Saunders Road at its junction is poor.  We propose a financial contribution (within the Section 106 agreement) to pay for the creation of a high quality footway on the western side of Penarth Road with crossing of Saunders Rd, to secure pedestrian safety and ease of movement when changing buses.

11. Security under major incidents

We see no planning for bomb alerts and ‘terrorist’ attack; the interchange would be attractive and vulnerable.  Emergency evacuation of bus-user crowds require good information, coordination and trained staff.  We require a condition that the developers guarantee and fund this.  

Cardiff &Vale Bus-User Group - Central Square Cardiff - replacement bus 'station' interchange
Objection to the Central 'Interchange' proposal 16/02731/MJR over lack of proper consideration to physical links with the Rail Station
Such a link is vital for an integrated transport interchange, recognised from the early outline plans.  The proposed design includes provision for an overhead bridge from the Interchange building to the rail station.  The amended plan includes the Central Square Visualisation which shows a canopy-covered walkway  physically connecting the proposed development with the frontage of listed Booking Hall. This was seen as a significant addition in the Press report of the amended plan. 
Though it depends on use of land owned by Network Rail and their agreement in conjunction with their plans for changes to the Booking Hall, the provision of a sheltered walkway needs to be secured via a Section-106 condition.

Impact on the listed building –  on the setting of the Rail Booking Hall
Both proposals – the Canopy-covered walkway and the overhead bridge – affect the setting of the Booking Hall.  The Council has duties under the Conservation and Listed Buildings Act to consider such impacts. 
The Council has also omitted to advertise these impacts of the development on the Listed Building, as is required under the Act.   In failing to consider the Council’s duties under the Planning (Listed Buildings and Conservation Areas) Act 1990, the officers’ report is wrong to recommend approval of this development.
Sections 16 and 66 of the Act require authorities considering applications for planning permission ... which affect a listed building to have special regard to certain matters, including the desirability of preserving the setting of the building ( Welsh Office Circular 61/96   Planning and the Historic Environment: Historic Buildings and Conservation Areas, s.11).  The words “special regard” are established in case-law to mean that officers cannot presume that the conservation objectives will be outweighed by having the Walkway as a planning objective.
Para. 8.18-20 of the Report covers impact on the setting of the listed buildings.  It says
The height and massing of the office building is designed to reduce the impact
of the building on Central Square and on the setting of the listed station
building. The office building is physically separated from the PRS building.
It omits to consider physical links to the Booking Hall, perhaps because it (and the ES) took the plans without overbridge and canopy-covered walkway.

Alternative for the walkway link
The canopy-covered walkway is deficient in respect of the change in level (the Interchange building being significantly lower than the Booking Hall) and being open to winds, which can be strong and gusty.   Adding shelter from winds would obstruct pedestrian and cycling movements between Saunders Road and Central Square.
The alternative of a walkway in a shallow tunnel with escalator up inside the Booking Hall (or just outside it) has still to be considered.  It may require a down-escalator inside the Interchange building.

Conclusion
One or more physical links between the Interchange and the Rail Station are envisaged and indeed required for a “world class” transport interchange.  This requirement needs to be covered in a s.106 condition on the development.  The Council duty to consider impacts of such physical links on the setting of the listed building, the station Booking Hal, have not so far been met.  The sub-ground alternative that would have zero or minimal impact has not been considered, but would require modifications to the Interchange design. 


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