We had high hopes for the proposed development at York Central. As a major development next to the station and enjoying a privilege unusual for York – a blank slate – the potential for York Central to be a showcase of sustainability while respecting York’s heritage greatly excited us. We therefore engaged with the consultation at an early stage, helping to organise a guided cycle ride to and from the site as part of the excellent MyYorkCentral consultation process, and making several written and oral representations to Council officers, Councillors and the York Central Partnership to try to ensure that the voices and needs of York’s cyclists were heard.
The clear messages on transport from York residents to MyYorkCentral were a strong preference for a low-car development that provided safe, direct and accessible routes for pedestrians and cyclists. The organisation responsible for development proposals on the site, the York Central Partnership (YCP), appeared to acknowledge this and the initial signs were that it would design its proposals accordingly.
Sadly, the outline planning application that YCP have now submitted has dashed these hopes. Very simply, we see the proposals as being more typical of the 1970s, where streets were designed with convenience for motor vehicles in mind, not people. This makes the proposals contrary to that demanded by the thousands of responses to MyYorkCentral, our persistent representations and indeed the economic and environmental challenges of the 21st century. With heavy heart therefore we have no alternative but to submit an objection, which we have done.
But we remain hopeful: if City of York Council planning officers can be persuaded to recommend approval of the application only on the condition that the proposals are re-orientated around the needs of York’s people, not motor vehicles, we hope that the potential of York Central can still be realised. We therefore urge you to submit your own objections, using some or all of the arguments summarised below (we append our detailed objection in full at the end of this post for your information). Although the statutory deadline for comments on this application was on Friday 28 September, the City of York Council are still accepting comments on this application for at least another two weeks or so after this deadline. You can view the outline application in full at the Planning Portal – search for the reference number 18/01884/OUTM. You can then email your comments to yorkcentralapplication (at) york (dot) gov (dot) uk. Make sure you provide a name and address when submitting a comment/objection. Arguments you may consider making are:
- In failing to provide safe, separated cycleways throughout the site, the proposals do not “give priority first to pedestrian and cycle movements” as required by paragraph 110(a) of the National Planning Policy Framework;
- The proposed use of shared space for cyclists and pedestrians is contrary to both DfT guidance and the Design Guide for York Central agreed by the Leader and Deputy Leader of the City of York Council at a public meeting on 6 August 2018;
- The flawed transport modelling presented in support of this outline application greatly underestimates the amount of congestion these proposals would result in, as the York Environment Forum‘s comment sets out. Such extra traffic on York’s roads would further dissuade less confident cyclists from cycling around York. The transport modelling for these proposals therefore needs to be updated with more realistic assumptions, and the provision for access for motorised vehicles to and through York Central amended accordingly.
Our full, detailed, comment on the outline application follows below.
Dear City of York Council Planning Officers,
We have always welcomed the opportunities that a development in York Central could bring to York and its residents. As the first glimpse of our city that many new arrivals will have, a well-designed development at York Central could act as a stirring showcase of how our city looks to the future while respecting its past. One whose buildings and infrastructure work for people of all ages, gender and abilities, and whose spaces nurture communities and are attractive places to linger, socialise in and savour. Though the initial designs consulted on have fallen far short of this, we have continued to engage at every step of the decision-making process in the hope of securing a York Central development that meets this easily-implementable vision.
We are greatly disappointed therefore to note that little, if any, of the substantive proposals on access in this outline planning application for York Central have changed in response to the many representations from the York Cycle Campaign and others, particularly through the outstanding MyYorkCentral consultation process. While we remain hopeful that changes can still be made to these designs, we are left with no choice but to object to the planning application in its current form until and unless its shortcomings in planning and other terms are remedied. We list these shortcomings and suggested remedies in the remainder of this response.
As an organisation representing York’s cyclists, we are obviously most concerned with the proposed facilities for cyclists. However, we have worked closely with other community groups in York who are similarly interested in the proposed development of York Central, and we share their concerns and analysis, particularly around the transport modelling which does not appear to us to be a realistic or robust representation of the likely impact of York Central in transport terms. Before setting out the shortcomings of these proposals for cyclists in planning and other terms, we wish to make clear that we endorse the response of the York Environment Forum, particularly its powerful critique of the modelled impacts on York’s road network from the proposed York Central development.
The failures of this application to adhere to the requirements of the National Planning Policy Framework
Ultimately, the failings of these proposals for cyclists come down to the proposals’ failure to meet the requirements of paragraph 110(a)-(c) of the revised National Planning Policy Framework (2018), a paragraph that the application states in full (see page 30 of the Travel Plan) but oddly declines to demonstrate how its proposals adhere to these requirements. As you will be aware, in the absence of an adopted Local Plan for York, the National Planning Policy Framework is the pertinent planning law against which the merits of this application must be judged.
For ease of reference, we replicate paragraph 110(a)-(c) below:
“Within this context, applications for development should:
- a) give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and second – so far as possible – to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use;
- b) address the needs of people with disabilities and reduced mobility in relation to all modes of transport;
- c) create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards;”
It should be quite clear however, that cycle movements have not been prioritised alongside pedestrian movements “both within the scheme and with neighbouring areas.” Indeed, on page 78 of the application’s Design Guide as submitted, there is no mention of the need to “first prioritise cycle movements.” Instead, it is simply stated that “Pedestrian movement should be prioritised at all times.” Because paragraph 110(a) states that “applications… should give priority first to pedestrian and cycle movements” (emphasis added), to prioritise only pedestrian movements is a direct contravention of the National Planning Policy Framework.
The failure to “first prioritise pedestrian and cycle movements” can be seen throughout the proposals. Much is made in the various documents submitted in support of this application of the proposed segregated cycleway along the primary route. But the fact is that no such provision is made on secondary routes, a point acknowledged (albeit sometimes in promising yet meaningless language, such as describing painted cycle lanes are high quality) in many of the documents in support of this application e.g. page 31 of the Sustainability Statement. Instead, cyclists are expected to share the space with motor vehicles, albeit vehicles subject to 20 mph limits (which DfT research shows that most motorists do not respect). Quite simply, that is not “first prioritis[ing] pedestrian and cycle movements”, it is imposing a pre-NPPF arrangement where cars dominate and cyclists are expected to adapt or not use the space. As we explain shortly, surveys on the attitudes of would-be cyclists repeatedly demonstrate a clear preference to be separated from motor traffic, with groups currently underrepresented amongst York’s cyclists, such as women, disabled, elderly and very young people, having particularly strong preferences for this separation.
Further examples of where this planning application falls short of the NPPF’s requirement to “first prioritise pedestrian and cycle movements” include:
- The lengthy diversion that pedestrians and cyclists would face in the event of the National Rail Museum expanding across Leeman Road (we back the York Environment Forum’s strong rebuttal of the delays that the applicants claim pedestrians and cyclists will face as a result, and similarly endorse their own estimated delays that pedestrians and cyclists would actually face);
- The suggestion that cyclists could use the riverside path to mitigate against the extra delays imposed by the diversion of Leeman Road caused by the NRM’s expansion. As the application acknowledges, this riverside path is prone to flooding, rendering it impassable to cyclists at certain points of the year (page 11, fourth paragraph under section 2.6 ‘Cycling Infrastructure’ in the ‘York Central Transport Assessment’);
- The apparent attempt to amend paragraph 110(c) of the NPPF – the requirement that conflict between “pedestrians, cyclists and vehicles” should be minimised – to merely when doing so is “feasible” (page 25 of Part 1 of the Transport Assessment, before section 3.2 on the National Planning Practice Guidance (‘PPG’)”;
- The reliance on giving people information about their journey options as a means of encouraging them to “travel in a responsible manner” (last paragraph, page 26, ‘York Central Transport Assessment’). This does not “first prioritise pedestrian and cycle movements” as required by the NPPF as research repeatedly shows that segregated cycle infrastructure (the kind that could easily be provided in a blank slate development like York Central) is the single most effective way to encourage those currently underrepresented amongst those who cycle in York – women, disabled, very young and elderly people – to cycle. For example, see the 56 studies reviewed in recent DfT-published research (pages 13-15, ‘National propensity to cycle: executive summary’, DfT, 2018), which all confirmed this preference for segregated infrastructure and 24 of which “reported statistically significant evidence that women expressed stronger preferences for segregation from motor vehicles than did men.” This therefore means that for the majority of such would-be cyclists, Figure 202 in the Design and Access Statement, showing a cyclist cycling on a painted on-road cycle lane, is not as claimed by the applicant, “cycle-friendly road infrastructure”;
The proposals for cycle parking on the site
The application proposes to provide cycle parking slots in line with CoYC guidelines, however the Campaign hopes that it can be acknowledged that CoYC guidelines do not fully cater for the wide range of bikes that can be found around York. The Campaign strongly urges, on the grounds of Equality, that parking is designed accommodate non-standard frame bikes such as those often employed by people with disabilities or travelling with young children. (Table 8, page 40)
The proposed hierarchy of streets and their implications for cyclists
We applaud the intent to create a hierarchy of streets and that traffic will be encouraged to use main roads and discouraged from secondary and tertiary roads (Design Guide part 2 of 4, page 78). However, we don’t believe that enough measures have been put in place to ensure that drivers follow this hierarchy, and we don’t feel that sufficient provision has been given to pedestrians and cyclists on some of the secondary and tertiary streets.
In particular we are greatly concerned by the lack of measures in place to prevent drivers from taking a short-cut from Water End Road, through the Salisbury Terrace Area and out via the Leeman Road underpass. Although the Saturn model does not indicate that this is likely to be a problem it is important to remember that the Saturn model is an ‘optimisation’ model, and it does not take into account human behaviour and the way in which people use local knowledge. It is inevitable that this secondary route will become a short-cut for drivers (particularly at peak times). This will make many of the secondary and tertiary roads in this area much busier than anticipated, and consequently more dangerous for pedestrians and cyclists.
We would like to see planners consider making this area a no-through road for motor vehicles (whilst allowing access & egress to its residents in both directions), to avoid it being used as a shortcut, and making it considerably safer for pedestrians and cyclists.
It is not clear what provision there is for pedestrians and cyclists at the Leeman Road underpass, but at a minimum there needs to be a dedicated footpath for pedestrians and a dedicated segregated cycle path for cyclists, at this potentially busy pinch point.
When it comes to provision for cyclists we are dismayed to see that there is no cycle provision going south-north through the development. Instead the design guide states the following:
4.4.2 Cycling on the carriageway
Secondary Streets and tertiary streets shall be lower in speed and predominantly residential in nature therefore cycle lanes shall not be marked on the carriageway.
4.4.4 Cycle safe streets
Tertiary and access streets shall be designed in a way that facilitates safe cycling within the roadway.
Travelling north-south through the development will be an obvious desire line for cyclists. There is clear evidence that adults cycling with children are deterred from cycling on roads (even when those roads are quiet). (Eg R Aldred, European Journal of Transport & Infrastructure Research, 2015, 15 (2) ). Similarly many other under-represented groups including disabled cyclists, elderly cyclists and women do not feel safe cycling on roads. By failing to provide segregated cycle infrastructure the applicants are again failing their obligations under the Equality Act 2010, as well as failing to meet the NPPF requirements to give priority first to pedestrian and cycle movements.
We ask that the applicant provides at least one segregated cycle route in the north-south direction, and that at a minimum secondary roads provide stepped cycleways or off-road cycle paths clearly differentiated from pavement with painted, continuous, white lines.
The proposed provision of shared space
In a number of areas of the development the design guide indicates that pedestrians and cyclists are expected to share space. For example page 82 of the Design Guide (part 2 of 4) states that ‘cycling is promoted site wide with space shared with pedestrians throughout the site’.
This explicitly goes against the revised DfT guidance and the recommendation that the implementation of shared space schemes should be paused, until the independent evaluation referred to above has taken place. For ease of reference we replicate this advice below:
‘DPTAC Position on Shared Space (13th June 2018)
The government – via collaborative working between the DFT and DCLG – should take a lead role in the shared space agenda, including commissioning further research, and should not leave matters entirely to be dealt with by local authorities.
LTN 1/11 should be replaced by new guidance, with extensive input from disabled people.
Existing shared space schemes should be the subject of detailed independent evaluation, evidence gathering and impact assessments, with the involvement of disabled people.
Evidence gathering should include accidents occurring within shared space schemes, together with comparative data from other road layouts. This could be achieved by redesigning the STATS 19 form used by the police to record road traffic collisions.
The implementation of shared space schemes should be paused, until the independent evaluation referred to above has taken place.
If shared space schemes are to continue in the future, disabled people need to be fully involved in their conception, planning, design, implementation and evaluation.
Those involved in shared space schemes need to be cognisant of the need to comply with the Public Sector Equality Duty and the duty to implement reasonable adjustments.
The interests of those with a wide range of conditions, including mental health and neuro-diverse conditions, and learning disability, need to be considered in the wider context of shared space schemes.
The government should bring forward regulations under section 22(2) (a) of the Equality Act 2010 to specify that organisations which fail to comply with new shared space guidance will not be considered to have taken reasonable steps for purposes of the duty to make reasonable adjustments, in order to make it easier for disabled people to establish discrimination contrary to section 21 of the Equality Act 2010.
The government should ensure that advice is readily available on how to challenge local authorities on existing or new shared space schemes which exclude or have the potential to exclude disabled people.
There should be a public education campaign to promote safer and appropriate use of current shared space by all (pedestrians, wheelchair users and motorists included).
The term shared space should be retained. However, there needs to be a clear and agreed definition of what is meant by ‘shared space’.
Disabled Persons Transport Advisory Committee
The proposed use of shared space is also contrary to the York Central Design Guide, agreed by the Leader and Deputy Leader of City of York Council, which states that mixing of cyclists and pedestrians in unmarked situations is to be discouraged.
There is strong evidence, recently gathered and presented by the House of Commons Women and Equality Committee (https://publications.parliament.uk/pa/cm201617/cmselect/cmwomeq/631/631.pdf) that shared space is hugely disadvantageous for many disabled people, and it goes on to suggest that Local Authorities are failing in their obligations under the Equality Act 2010 when making decisions of shared space schemes.
We ask that the applicant reconsiders the areas marked as shared space, and follows their own design guidelines in providing separate spaces for pedestrians and cyclists.
The proposals for the Marble Arch Tunnel
We note the applicant’s are proposing the option 2 solution for the Leeman Road (Marble Arch) Tunnel into the city centre. This provides a segregated two way cycle route through the main tunnel along with single way working for all other traffic. It dedicates the side tunnel purely to pedestrians. We support having a properly segregated cycle route and the dedicated pedestrian tunnel, but consider that allowing all traffic to continue to use the single way working should be resisted (and reference the detailed objection submitted by York Environment Forum arguing why the applicants analysis and support for this option is flawed). The tunnel is deeply unattractive and fume laden as it is. Frankly only clean vehicles ought to be allowed through it in terms of providing a healthy environment for the primary cycling link to and from town. However the proposal to retain this as a major traffic route is flawed anyway, encouraging more traffic into the completely overloaded Lendal Gyratory, and failing to provide the constraint on traffic as part of encouraging a low car 21st Century city centre development at York Central. Additionally the two way arrangement will engender significant queuing on the approach roads at busy times, which means cyclists will have to contend with queuing vehicles on the narrow road leading up to / from the Lendal gyratory will cause major difficulties for cyclists getting past and will discourage less confident cyclists. It will not provide the right entrance to what should be a jewel development in York’s crown.
We also see merit in the idea recently advocated by the York Bus Forum and in the Environment Forum’s objection for a separate walking / cycling link across the west end of the station connecting Queen Street direct to York Central. This would offer a much more direct and acceptable route for cyclists and pedestrians travelling from the south and west sides of the city to and from York Central avoiding the Lendal gyratory entirely.
In sum, despite having worked hard to try to ensure York Central meets the needs of York’s cyclists present and future, we are greatly disappointed to note that the outline application submitted falls far short of these needs. We therefore object to this application until and unless the concerns listed in this response are remedied in the manner suggested.