York Green Party is objecting to the current planning application for York Central road access as it is a car based development that will increase traffic in the centre of York at a time when we need to be reducing it. This is the objection. You can use it as the basis for your own objection either by emailing firstname.lastname@example.org or on the planning portal here
We support the principle of a new access road to provide necessary access to the site as the existing road network, particularly through Salisbury Terrace, is height restricted with railway bridges and inappropriate for the scale of the development.
However, we object to the current proposals as they stand which we believe will have a disastrous negative impact on traffic levels, congestion and air pollution on the new site, in the areas around the site and in the city centre as a whole. These proposals will result in a car dominated development with new public realm blighted at peak times by long lines of queuing traffic and contributing to gridlock in the city’s transport network. This is a huge missed opportunity which if left unchanged will result in a 20th century rather than a 21st century development. We believe the transport assessment demonstrates that it will completely fail to meet the transport objectives in the draft Local Plan: “ To reduce pollution, noise and physical impact of traffic by restraining growth in the use of motor vehicles”
Climate change and congestion
City of York Council has declared a Climate Emergency with a target to reach zero carbon by 2030. Transport currently accounts for more than a third of CO2 emissions, (the majority of that from road transport) and also for around 40% of energy demand. Recent work by West Yorkshire Combined Authority in conjunction with the York and N. Yorkshire Local Enterprise Partnership indicates that the Emission Reduction Pathway requires a 43% reduction in private car use by 2030 (regardless of fuel type) with 30% of remaining car use shifted to active travel by a 10% increase in bus use and 60% increase in cycling and walking.
In terms of CO2 emissions, most cars on the road are still fossil fuelled and therefore still emitting CO2 emissions (quite apart from the emissions involved in manufacture of all vehicles). The switch to all electric is predicted to take until somewhere between 2030 and 2040. This development is due to start building out by 2023 or sooner. It is accepted amongst transport professionals that new (through) roads create more traffic (Phil Goodwin, Induced Traffic Again, and Again and Again 2006; ‘Beyond Transport Infrastructure’ 2006 report by independent consultants for the Countryside Agency and CPRE; SACTRA report 1994 ‘Trunk Roads and the Generation of Traffic; ‘The Impact of Road Projects in England Report’ by independent consultants TfQL for CPRE 2017.)
It is unthinkable to launch a major new flagship development that is designed on the basis that the traffic levels passing through the development and onwards into the city centre traffic network will be maintained through to 2033 at the same levels of congestion we now experience.
A development dominated by traffic queues
Yet this is a proposal for a development dominated by traffic queues. It is predicated on providing for traffic levels that will result in peak congestion levels in 2033as high as we see now on Gillygate and St Leonard’s Place with traffic queues at peak times through the new ‘Square’, along Cinder Street and back along the new access road that will separate many new residents from the Great Park. These queues will be as long as the current queues back from Micklegate Bar to the Knavesmire and will reach back around halfway down the new Park Street.
Electric vehicles won’t solve this problem
Any assumption that a switch to all electric vehicles will make these planned congestion levels acceptable is deeply flawed for the following reasons:
- The slow timescale for the switch to all electric.
- The impact on pollution levels and air quality on the site, in surrounding neighbourhoods and throughout the city. Whilst petrol and diesel emissions will gradually diminish over time they will still be with us for many years at the start of the new development. At the same time, there is now clear evidence that all vehicles emit dangerous micro-particles [PM 2.5] as a consequence of tyre wear and braking. High levels of congestion will mean continued bad air quality whatever the vehicle fuel.
- There is clear evidence that whilst we can reach zero carbon and maintain a good quality of life, the energy ‘mix’ to achieve this has to include a significant reduction in overall energy use/demand. We can do this by thinking and acting ‘smarter’ in all kinds of ways, but it isn’t feasible to simply transfer existing levels of transport related energy demand to electric. We have to also reduce demand – https://www.cat.org.uk/info-resources/zero-carbon-britain/research-reports/zero-carbon-britain-rising-to-the-climate-emergency/ .
- The planned levels of traffic congestion will not support the vision of a high quality, attractive development with pleasant, active neighbourhoods that encourage walking, cycling and neighbourliness. The current proposals will see lines of standing traffic through the so-called flagship new square (Museum Square) and long peak time queues along much of the length of the new access road, cutting off pedestrians from the new park – with no pedestrian priority planned for the new road and cyclists having to travel past lines of polluting traffic.
- There is clear evidence that traffic congestion undermines local economies and costs businesses money. It is therefore hard to understand why, particularly at a time when our local economy faces huge challenges following coronavirus, that we would design a development that assumes increasing congestion levels.
- In the face of the current recession resulting from coronavirus the competition to attract high quality employers to invest in the site and to realise value from the sale of properties is going to be even higher than previously. The key to this for York will be to demonstrate a clear vision to ‘Build Back Better’ and to market a site with a high quality of life that will be part of the solution, not part of the problem. Long lines of queuing traffic (whatever fuel they are using) will not deliver this aspiration.
This is a massive missed opportunity to capitalise on the potential to increase walking and cycling levels in the aftermath of the coronavirus crisis. Government policy – statutory guidance – was announced by the Secretary of State for Transport on May 9th 2020, with accompanying funding streams to reallocate roadspace to walking and cycling by amongst other actions ‘closing roads or residential neighbourhoods to through motor traffic or restricting access.’ .
Recent experience of low traffic levels and a 70% increase in cycling through the coronavirus lockdown has clearly demonstrated that a new development without vehicle domination would quickly attract significant levels of cycling and walking – particularly given its location near to city centre facilities, on-site employment opportunities and public transport networks. Government encouragement to promote walking and cycling and new design standards following the corona virus crisis will help to raise expectations that this new area of the city will be an exemplar of 21st century mobility, based around active travel, increased home working, proximity to workplaces, proximity to the railway station and the smart use of new technologies.
DETAILED COMMENTS ON THE CURRENT PROPOSALS
Cinder Street traffic levels and severance. According to the modelling submitted with the application predicted peak traffic levels on Cinder Street by 2033 will reach 1100 vehicles/hour – the same as pre CV19 on Gillygate. At Cinder Street pedestrians will be faced with a dangerous crossing over 2 lanes of traffic and a bus lane to get from one side to the other. At peak times traffic queues will stretch back for up to 800 metres – beyond the 500 metre length of the bus lane meaning that buses could be significantly delayed before reaching the start of the bus lane. This is unacceptable for all the reasons outlined above.
Museum Square traffic levels and severance. The peak at Museum Square by 2033 is predicted as 900 vehicles/hour – the same as St Leonard’s Place now. Traffic queues for much of the day will cut the new square in half, stretching back from the station for up to 800 metres (the equivalent of a queue from Micklegate Bar back to the Knavesmire). Contrary to the sparsely populated illustrative drawings, this will undermine any notion of high-quality public realm creating a world class arrival point to York Central and the NRM from the railway station. The need for a controlled pedestrian crossing at this point, even with frequent pedestrian phases, only underlines the fact this is still being designed as an old-fashioned car-dominated space.
Park Street traffic levels and severance. Park Street itself also underlines the car-based nature of the current scheme. Pedestrians will be offered 7 ‘courtesy crossing points’ with colourful road markings at intervals along the road in order to reach the Great Park. Whilst we support the use of colourful crossings in the right places, given the forecast traffic levels this clearly puts pedestrians low down the transport hierarchy and cars at the top. Pedestrians will need to depend on car drivers intent on their commute allowing them to cross. The applicants’ argument that a 20mph limit and coloured surfaces will be sufficient to make drivers give way to pedestrians is not borne out by experience elsewhere. This is not pedestrian priority and not in keeping with the transport hierarchy. According to the application, kerbside noise levels alongside the Great Park will be 70 decibels at peak times including Saturdays, which will be highly intrusive to the enjoyment of the park and adjacent residential properties.
Leeman Road Tunnel and impact on city wide network. Leeman Road Tunnel/Marble Arch would have a capacity of 1000 vehicles/hour and is predicted in this application to have 900 vehicles/hour during the peak. This is very close to the maximum and therefore will be very sensitive to any breakdowns or traffic incidents, which will immediately impact on the Lendal Arch gyratory and from there on the whole transport network city wide. The current modelling implies that by 2033 the gyratory will have outward bound queues blocking it for up to 40 minutes in the peak.
Negative impact on public transport. The length of these traffic queues will have a very damaging effect on public transport through the site as well as the quality of the whole development. 800 metre queues along Cinder Street/Park Road will mean that the currently proposed 500 metre bus lane will not be effective, with in-bound buses needing to queue to get into it for up to 30 minutes in each morning peak. Queues in the other direction from the Lendal Arch gyratory will also prevent buses from running on time, meaning the services through the site and those on Station Road going to other destinations will have the same or worse problems than those we face today in the rest of the city in terms of reliability and timeliness.
Salisbury Terrace The current proposal maintains all traffic access through these narrow, terraced streets onto the new spine road from Leeman Road via the Leeman Road Link. Modelling indicates a 35% – 55% increase in traffic travelling west from Clifton Green on this route. This will worsen air quality, and noise and create the opposite of a low car neighbourhood, another missed opportunity for residents of this area to transform their quality of life.
POTENTIAL SOLUTIONS / CHANGES NEEDED TO THE CURRENT APPLICATION.
York residents have indicated that they support the development of York Central as an exemplar low carbon development, as has been portrayed in much of the promotional literature. This application needs to reflect that aspiration and ensure that sustainable transport has the highest priority within the design concepts.
This application doesn’t need to go right back to the drawing board to make the proposals far more sustainable and appropriate for a 21st century low carbon development. This can be done through a number of key changes.
Real world modelling. York residents have a right to see modelling based on the introduction of these measures in 2022 and each year thereafter, taking into account real world scenarios including the Climate Emergency, the growing pressure from the public for sustainable lifestyles and the aftermath of the corona virus crisis, including Government support for increasing walking and cycling and the short term challenges for public transport. The shift towards more home working and reduced international travel could become part of the ‘new normal’. It is essential for the short to medium term impacts of the development as well as the consequences for the long term to be taken into account from the beginning. Modelling should be clearly focussed on underpinning a low carbon development, not simply projecting forward pre CV19 travel patterns and assumptions.
Air quality assessments. The current assessments regarding air quality are inadequate. They don’t sufficiently consider the impact of the long queues on Park Street and Cinder Street on cyclists and pedestrians alongside the traffic. There is also no assessment of air quality in the Leeman Road Tunnel where again cyclists will be impacted by high levels of traffic at peak times. These assessments should be provided for all relevant air quality measures relating to traffic pollution. An argument that an assessment of air quality in these locations is not a statutory requirement (as there are no permanent ‘receptors’ ie people living in the immediate vicinity) is not good enough. As a council and as a planning authority there is a responsibility for the health and well being of all residents in all circumstances. These air quality assessments should be provided and the whole area declared a ultra low emission zone for all vehicles.
Leeman Road Tunnel/Marble Arch. Overall it is clear that the key to reducing traffic levels throughout the site is to ensure that there is no peak-time through route to the city centre and beyond. It is the route through Leeman Road Tunnel for general motorised traffic that is the key determinant of projected peak traffic levels throughout the site, surrounding areas and the city centre and the key issue in this planning application.
Allowing inbound and outward bound flows for all types of traffic through the single lane tunnel during peak periods is what underpins the very high traffic projections. Even with single lane working through the tunnel to make room for improved provision for walking and cycling the modelling shows that current high congestion levels on Holgate Road still lead to high levels of traffic commuting through the new site to the city centre and beyond.
And yet the potential impact shown in the modelling on city centre traffic, the Lendal Arch gyratory and the wider traffic network is truly alarming – with the modelling showing the additional traffic will frequently create gridlock around the gyratory at peak periods (and often in the wider network too).
The only way to keep traffic levels down is to restrict access for general traffic through Marble Arch by installing a bus gate, which supports access for cycling walking, public transport (and potentially other specified vehicles) but restricts general traffic. This could operate during peak times only, at peak times + other times to be determined or 24/7, but the infrastructure needs to be there from the outset as part of the development, before the new road is opened to any traffic. This would result in significantly reduced traffic levels passing through the new site, improve air quality, efficient bus services, encourage walking and cycling, improve the experience of visitors arriving in York from the railway station to ‘Museum Square’ and visiting the National Railway Museum, improve the quality of life for new residents on the site and their ability to access and benefit from the potential health benefits of the Great Park and Millennium Green.
It will obviously make it possible to vastly improve public transport provision through the site, making this more attractive than car travel for many, (including those going to York Central, the City Centre and beyond) with more frequent buses able to run reliably on time. It will vastly improve the experience of cycling along the access road (and via routes through Salisbury Terrace and Jubilee Terrace towards the city), greatly reducing pollution from vehicle traffic – and will make walking around the site a far more enjoyable experience for residents and visitors.
Low traffic levels through the site which facilitate excellent public transport services and healthy cycling will also help to attract those currently driving down Holgate Road and Water End as commuters to choose more active and less polluting options with faster travel times. Additionally, plans to support excellent public transport provision in the medium to longer term are particularly important in the aftermath of the corona virus.
Leeman Road residents. Clearly both the currently proposed changes and the further addition of a bus gate would provide some changes and challenges for residents who currently live in the Leeman Road area and we sympathise with that. However, we believe that these challenges could be addressed through exploring a range of options with existing residents. These could include decisions around whether the bus-gate should be full or part-time; the possibility of ‘grandfather’ rights for existing residents allowing them to pass through the bus gate in motor vehicles at certain times of the day, or other potential options residents might suggest. Leeman Road residents will still in any case be able to access the railway station by car if needed via the Leeman Road Link Road and the access road or to exit Leeman Road via Salisbury Terrace onto Water End. Again, much lower traffic levels on the access road and throughout the site would offer a much less congested journey and mean that bus services running via Salisbury Terrace, the link road and to the railway station would be much quicker and more reliable.
The bus lane. The addition of a 500m bus lane to the current application is a sticking plaster solution to try to mitigate the impacts of a bad design being put forward from Day 1 of a new development and still fails to address outbound delays in the evening peak. We have the opportunity now to get this right in the first place! Were the application to be approved more or less as it currently is, it would be better to have the bus lane than not – but essentially it is a sign of failure. A far, far more cost-effective solution would be the bus gate, which would remove the need for a bus lane. However, it would still be preferable to keep the land now allocated to the bus lane to further improve the pedestrian environment in that area.
Salisbury Terrace If the current application were to go forward as it is we would have serious concerns about the impact on Salisbury Terrace and surrounding streets. There will be a considerable incentive for additional traffic to cut through from Water End/Clifton Green in order to jump the queue on Park Street via the link road. Should the current proposal go ahead with no bus gate at Marble Arch we believe there will be a need to consider a bus gate in the vicinity of the Link Road, at least in peak times, potentially with resident passes. If the bus gate were in place at Marble Arch of course, the necessity to consider further restrictions for Salisbury Terrace would be far less.
Walking & cycling routes – We support proposals to provide fully inclusive pedestrian and cycle access from Wilton Rise to the west and would urge that this is considered as a key traffic free through route linking to the city centre as well as York Central. Its design should be such that it has priority over vehicular access points and is a focal axis for development and public realm.
WHY WE NEED ACTION FROM DAY 1
It is crucial that we get this right from the outset. Traffic levels on Holgate Road, other roads around the site and in the city centre are unacceptably high in terms of climate change, air quality, quality of life in our neighbourhoods and our overall social and economic well being. Recent experience during lockdown has shown many people the advantages of quieter traffic free streets, but traffic levels are already starting to rise again. We have the opportunity here to create a 21st century zero carbon, low car development in keeping with the Council motion passed in July 2019 with cross party support. This will not only create pleasant neighbourhoods for new occupants but can also help us reduce traffic levels in surrounding neighbourhoods through facilitating a high quality bus priority route from the west into the city centre.
This has to start from the first day that the new road system is open and therefore has to be a core requirement of the planning application now. If commuters start using this through route at peak times it will be difficult subsequently to introduce greater restraint.
On the other hand, by giving priority to active travel and public transport through the site and into the city centre we can start the process of giving people more real options to leave their cars at home and transfer to other modes of travel. It will also influence travel patterns as new residential and commercial properties start to be occupied, making it much easier to achieve the modal shift required over the coming years up to 2030.
This will make a big contribution to improving quality of life in existing neighbourhoods and the city as a whole.
In conclusion the application in its present form would seriously undermine the quality of the development and the climate change targets that the city has set for 2030. We believe these questions and challenges need to be resolved before full approval is granted in order for this development to meet the aspirations within the draft Local Plan and the design guide approved as part of the outline application.