York Central still fails to create an exemplary high-quality low carbon area

Andreas and Lars at Marble Arch, York Central

York Council
Green Group has submitted another objection to the York Central outline
planning application as more and more details emerge, saying that even with the
proposed amendments it is still not good enough to be approved.

Green councillor for Micklegate ward Cllr Kramm 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 20th-century solutions for 21st-century
problems. It is not helping to solve York’s transport and traffic problems but
will add to them. The citizens of York have been promised ambitious, imaginative
and high-quality design, but what we get here is the same old, same old.”

In their objections York Green Party supports the detailed
responses on transport matters submitted by York Civic Trust Planning
Committee, supports a bespoke park & ride service for the site and a bus
gate arrangement at peak times at Marble Arch to provide sufficient public
transport priority. The Greens have also pointed out that the travel plan risks
creating very high traffic levels during the early development phases if there
are not strict requirements for sustainable transport to be provided as part of
each and every phase of the development.

Micklegate Green Party candidate Rosie Baker says “If through traffic isn’t prevented at peak times and new site occupants are not offered sustainable transport option more attractive than the private car, this is only going to create further traffic chaos for residents and commuters in the west of the city.”

Lars and Andreas, Marble Arch

Full Comments of York
Green Party for Planning Application 18/01884/OUTM on 19 February 2019:

York Green Party reasserts previous objections and supports
the detailed responses on transport matters as submitted by York Civic Trust
Planning Committee, based on the expert advice and analysis by Prof Tony May.
In particular but not exclusively the proposals still fail to respond to the
brief of creating an exemplary high-quality low carbon new area of York. It
fails to create the conditions where public transport is of sufficiently high
quality to achieve the lower car mode share specified in the Framework Travel
Plan (Annex C) and the sustainable travel modes assessment (Ch7 Annex A).
Despite our previous comments that parking provision for the commercial
developments is excessive and should be largely replaced with a bespoke park
and ride service, there is still no clear commitment to such provision.
Moreover, commitment to the provision of a bus gate arrangement at peak times
at Marble Arch in combination with a far lower car trip generation rate for the
commercial element is the only realistic way to provide sufficient public
transport priority without creating extended delays on the rest of the network.
Such an arrangement would also remove incentives for through traffic to
continue using Salisbury Terrace as currently experienced. Removing trip
generation and thus peak time high levels of vehicle movement on the access
road is also key to creating a safe liveable environment for the new
residential area as well as creating the conditions where walking and cycling
are perceived to be safe and attractive for all age groups and abilities.

Whilst we welcome the significant reductions in car mode
share in The Framework Travel Plan we do not believe these are achievable
whilst maintaining the high quantum of parking provision next to the station
nor without cycling and public transport priority through Marble Arch. Given
the risks of generating additional car traffic and higher mode share during the
long development phase which could be a consequence of designing to 2030
projected traffic levels we suggest, there must be tighter conditions on
phasing for a series of time horizons linked to expected occupancy levels. In
each phase sustainable travel needs to be more attractive than private car use,
with frequent public transport including park and ride a priority and clearly
specified in the Framework Travel Plan. We urge the planning authority to
demand further revisions to respond to these points and the more detailed ones
made in Prof May’s submission.

Full Comments of York
Green Party for Planning Application 18/01884/OUTM on 1 October 2018:

York Green Party Objection to York Central 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.

Housing

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.

Community provision

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.

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