York Council Green Group has submitted an objection to the York Central outline planning application, saying that in its current form it isn’t good enough to be approved.
Green councillor, Denise Craghill said ‘We have always supported the principle of this development which presents a tremendous opportunity for the city to provide a zero carbon sustainable development, providing high levels of affordable housing and a centre of innovation and creativity fit for the 21st century. This application is promising a traffic bound 20th century development with limited imagination or vision.
In many respects this could be easily improved by a number of key changes. These would include going for option 3 at Marble Arch including a bus gate to prioritise public transport and prevent general vehicle traffic through the site. We also need to drastically reduce parking provision in the Central Business District, which seems to be one of the main traffic generator’s for the spine road and replace it with far better dedicated park and ride services. We should remove on street parking, locating residential parking at the edges of the development and prioritising walking, cycling and play streets throughout the site.
We would also like to see far higher levels of affordable housing on this publicly owned site, clear mechanisms such as covenants to prevent the use of the new housing for holiday lets and selling on of affordable homes and the safeguarding of specified lots for on site educational and health provision. All buildings should be required to be to passivhaus standards, providing warm homes and very low energy bills.’
York Green Party objection: York Central outline consent 18/01884/OUTM
Transport and low car development
We have consistently argued for this brownfield site to be developed as an exemplar sustainable development but there is little evidence in this application of this approach. The application should demonstrate best practice for housing and commercial uses close to the mainline railway station which offers excellent regional, north-south and cross- country links. We believe the location and land ownership present an ideal opportunity to demonstrate that high internet connectivity, low energy use and sustainable transport can be designed in from the outset.
We feel that this presents a once in a generation opportunity to enable York to have our own unique equivalent of the Vauban District of Freiburg where the proportion of residents living without a car has increased over time from an initial 50% to around 70%, with nearly 60% of those now without a car having given up owning one on moving to the settlement. To follow this model would require the removal of all on-street parking and providing parking only in blocks at the entrance to residential areas. Also a street network designed to favour active modes of transport and designed to discourage car use. In Vauban stellplatzfrei – literally “free from parking spaces” streets allow vehicles to enter at walking pace to pick up and deliver but not to park. Such arrangements throughout the residential areas should ensure ‘play streets’ are safe for play but also link to a network of pedestrian and bike paths. These should all be routed through or past open spaces, with safe access for all ages to the linear park on the opposite side of the spine road. To achieve such a vision, traffic on the spine road should not exceed 400 vehicles per hour. The proposed rate of 1000 vehicles per hour completely undermines any claim that this is a sustainable development. With this rate of traffic flow, the minimum mitigation would be to have signal controlled pedestrian/ cycle toucan crossing points at regular intervals along the spine road.
We entirely endorse the transport representations from York Civic Trust and Environment Forum Transport Group (EFTG) and agree that this application completely fails to produce an appropriate 21st century transport solution for an intense development in the heart of York and misses a major opportunity for a world class exemplar of low traffic development. Instead of maximising the benefits this site could bring to addressing the City’s future economic development and its housing crisis, it threatens to create a completely unnecessary level of new vehicular traffic in the heart of the city that will unacceptably exacerbate the existing congestion and pollution problems and hence impose additional economic and health costs on residents and businesses. In order to comply with our public health strategies to tackle obesity, heart disease and diabetes a design for this new section of city should encourage and facilitate active travel in every way possible.
We agree with the EFTG that the transport design and modelling fails to adequately meet the tests in NPPF paras 108-111. The transport modelling within the Council’s Transport Topic Paper 2017 (part of the Local Plan submission) in itself fails to meet the challenge set in NPPF para109 with a projected 21% increase in car journeys by 2033. The modelling used in this application uses a similar flawed approach with no allowance for behaviour change. If the policies within the current LTP3, NPPF para110 and draft Local Plan policy T1 and T2b were properly applied to this development the traffic modelling could show significantly lower traffic impact on the wider network and Option 3 for ‘Marble Arch’ with a bus gate at peak times could be demonstrated to be workable without significant impact on key junctions. In order to comply with these tests, we believe that the modelling should be updated with revised assumptions for a ‘Vauban plus’ model.
A staged approach should be taken to demonstrate the impact on traffic levels at different points in the development, not just in 2033. For example (when the new access road first opens and caters for construction traffic, access to premises, existing rail users and NRM traffic, displaced bus services that currently run on Leeman Road (under Option 3 bus gate to operate weekday peak times only). This would give the opportunity for real life testing to influence travel behaviour patterns with maximum incentives in place for sustainable travel to and from the site.
Parking provision must also be carefully staged so as to incentivise the use of park and ride, car clubs, walking and cycling as each new phase of development is completed. The developer should be required to secure extended hours park and ride service from the first opening of the western access to the station and all new commercial operators required to include park and ride incentives as a key element of their travel plan. We endorse the view of EFTG that the Framework Travel Plan must include the removal of on street parking provision to centralised location(s) for the residential element, and must reduce the maximum parking standards so as to provide far less parking particularly near to the station, to be replaced by sufficient capacity at the park and ride site. We believe there is scope for a commercial arrangement between rail operators and park and ride such that prime land near the station could be freed for commercial development with a bespoke shuttle service (at key times eg early morning and after London train arrives about 10pm) from the park and ride site to the station. This might in time extend to other key central destinations such as York Hospital which has parking and congestion challenges. If this was introduced from the outset, and businesses and the NRM had the benefit of access to car club vehicles and a bike hub for daytime business use there would only be need for one multi-storey car park not two at the western entrance to the station, freeing up space for high quality public space within prestige commercial development (on a par with the Hiscox building for example). We would also support annual reporting of parking levels with a condition similar to that applied to Heslington East to finance the introduction of TRO’s and residents parking schemes to address any displacement into surrounding residential areas.
We also object to the proposal to close off walking and cycling access through the extended NRM site, currently Leeman Road. We accept the concept of removing vehicle traffic with alternative access links but feel pedestrian and cycle routes need to be enhanced not made longer. In particular pedestrian access through the gallery should be more aligned to the times of station access through to Scarborough Bridge – 5.30am -10.30pm. In order to avoid this element holding up the rest of the development we believe determination of the detail of continued access could be omitted from the outline application for future determination (once the detailed application for the rest of the site comes forward).
In respect of the options for ‘Marble Arch’ we strongly support the proposal to provide a separate two way cycle lane through the main tunnel allowing the existing smaller tunnel to be designated for pedestrians only. This is essential to cater for growing demand once the new accessible Scarborough Bridge route is opened, particularly if it links well with the wider cycle route network at either end, meaning that it will become a key part of routes extending safe sustainable access to other parts of the city. Linking this to a high capacity cycling network across the city will be crucial in providing greater incentives for active travel, helping to decouple economic growth in the city from car traffic growth. However we also consider it crucial that option 3 is applied to ensure that at least during peak weekday hours the tunnel is restricted to public transport and few other exceptions. Without this measure the new development will be over-run with existing through traffic, hampering the punctual movement of bus services, adding to air pollution within the site and perpetuating car based journeys to the city centre. The park and ride service will be less efficient and less attractive if it is not given priority at this key part of the route into the city centre. Exceptions might include postal delivery vehicles (until such time as the sorting office is relocated), emergency vehicles, refuse vehicles and taxis. Without implementing Option 3 the ‘vision’ of a new public square will be destroyed by permanent traffic queues through the middle of it, effectively splitting it into two insignificant polluted areas of hard landscaping.
We share concerns that the application offers only 20% affordable housing, which might be reduced further. Given the public sector control of this application we feel it is vital to maximise provision of social housing, including legal conditions to ensure that dwellings are occupied as residential first homes, not second homes or holiday lets. Shared ownership and affordable rent properties as well as discounted sale for key workers need to be provided and mechanisms secured to prevent them being sold on or re-let at inflated rates. This must be secured outline planning.
We welcome the idea of play streets (which should be throughout the residential areas and need to be protected from encroachment by through traffic and displacement parking) but feel more consideration should be given to allocating space for the educational and health needs of the new residents and workers. Schools provide meeting space and a sense of community which will not be created through families having to travel out of the area for their education and health needs. Such a facility also helps to ensure that the majority of residents can access these services by walking and cycling rather than driving to more distant provision. This needs to be acknowledged and appropriate sites safeguarded at this outline stage for educational and health use, even if the detail is left until reserved matters.
Sustainable design and construction.
The failure to specify the highest levels of sustainable building and use of renewables for all of the site is a huge missed opportunity. As well as helping to tackle climate change buildings should be affordable to live in. Passivhaus standards would provide very low energy bills. The failure to proceed with a District Heating System should be compensated for by other measures including the highest insulation standards, solar PV, ground and air source heats pumps and a ‘fabric first’ approach to achieve a zero carbon development.