Clifford’s Tower Planning Response

Planning was submitted in February for the latest section of the Castle Gateway masterplan, under the planning reference 22/00209/FULM. The proposals remove the car park at the base of Cliffords Tower replacing it with a multi-function landscaped area which extends to the Eye of York and along Tower Street in front of the Hilton hotel. Campaign members have assessed the proposals using the Cycling Level of Service tool provided in LTN 1/20 to form our response the application – which you can read in full below.

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1. Summary

This comment has been put together with the assistance of members of York Cycle Campaign, relating to the application for the ‘Public realm improvements to include new public square with provision for flexible events space with seating areas and water feature, creation of circular path to base of Clifford’s Tower, reconfiguration of Eye of York courtyard space, creation of elevated walkway to rear of Castle Museum and enhanced planting scheme throughout following removal of surface level car parking | Castle Car Park Castlegate York’. The comment looks at the proposed cycle routes (section 2) and proposed cycle parking (section 3).

The scheme shows improvements to cycling within the application boundary, which is in line with local and national policy notably; 

• NPPF paragraphs 85, 92, & 112, 
• Local Transport Note 1/20,
• Draft York Local Plan (2005) policies GP4a, T2a/b, T4, L4, V1, V3,
• Proposed York Local Plan (2018) policies DP2, DP3, D1, T1, T7, SS5.

On the whole the scheme makes a positive improvement, the Campaign wishes to Support the proposal, although there are points requiring further consideration which are outlined in detail in the sections below. 

2. Proposed Cycle Route

Local Transport Note 1/20, Cycle Infrastructure Design, recommends that cycle route proposals are assessed and scored using a Cycling Level of Service tool which is provided in Appendix A of that document. A completed assessment has not been included in the planning application, but with help of its members the Cycle Campaign has undertaken its own assessment of the proposed route using the tool which has formed our responses to the application in this section.

Tower Street has been assessed using the tool, which is broken into the five follow sections as follows;

• Cohesion measures how well connected the cycle route is to other sections of the cycle network, and how easy those connections are.
• Distance is a measure of how direct the route is, and how many delays cyclists encounter whilst using that route.
• Safety considers the appropriateness of the type of infrastructure along the route, in particular its relationship to motor vehicles.
• Comfort considers how comfortable the route is to ride physically in terms of materials used, as well as personal comfort in terms of width given and ease of wayfinding.
• Attractiveness section looks at how likely the cycle route is to attract people to use it.

2.1 Tower Street

Overall this area of the proposal scored 78%, over the recommended pass level of 70% and an improvement on the existing infrastructure which scored 65%. However CLoS tool raises some weaknesses which are discussed below.

2.1.1 Cohesion

There is no change in the scoring of the Cohesion section of the CLoS tool, with the area scoring 5 out 6 before and after.

The high score is due to being in a well connected part of the city, with cycling allowed for within the route.

The junction with Clifford Street could be improved to make it easier for cyclists to enter and exit the area.

2.1.2 Distance

There is no change in the scoring of the Distance section of the CLoS tool, with the area scoring 8 out 10 before and after. 

The route is direct and doesn’t inflict undue delays onto cyclists, but doesn’t provide any cycle specific facilities.

2.1.3 Safety

The Safety section of the CLoS tool has an increase in score from 7 to 11 out of 16.

The speed table and paving setts should help slow traffic and increase safety in the area, as will the removal of traffic using the Tower Car Park.

Cycles will be cycling along the outside of Blue Badge holder parking bays by the Hilton Hotel, so there are potential conflicts with drivers pulling out of bays. Arranging the bays in an echelon arrangement to encourage motorists to reverse in and drive out in a forward gear would improve visibility of passing cyclists.

The scheme should help to reduce conflict with kerbside activity by removing the taxi parking area on the south side of Tower Street. However as there is no dedicated drop-off area for the hotel, casual parking could present a problem.

2.1.4 Comfort

The Comfort section of the CLoS tool has an increase in score from 3 to 5 out of 6 possible points for items considered.

The proposed cycle track surface is proposed to be block paving rather than an asphalt surface. Depending on the material used this can have a lower slip-resistance which is critical in wet weather, and can be prone to becoming loose or unlevel over time. 

The material choice should be conditioned requiring further details, to ensure that the surface is of a high quality with a long-life span.

2.1.5 Attractiveness

There is no change in the scoring of the Attractiveness section of the CLoS tool, with the area scoring 7 out 8 before and after. 

With less traffic on Tower Street due to closure of the car park, its likely pedestrians will use the shared road space crossing to get to Cliffords Tower and the new public space.

During crowded periods there may be some conflict between cyclists and pedestrians in the shared use areas, although Tower Street is not a major route for cyclists so this seems unlikely, and the paving setts will act to define a changed use over a standard carriageway

3. Cycle Parking

3.1 Amount of parking

We have not been able to determine any indication of where or how much cycle parking will be provided on the general arrangement plans submitted, however, the submitted Design and Access states that all cycle parking within the vicinity will be retained, and temporary parking will be provided during events if required.

The Campaign counts 24 Sheffield type stands are currently installed on Tower Street, with a further 5 Sheffield type stands and 10 wheel-hoop stands by the Castle Museum, providing spaces for 68 cycles in total.

Whilst this sets the minimum of cycling spaces that should be replaced, we believe a full assessment should be made using Appendix E of the Draft Local Plan (2005) to determine the amount of cycle spaces that should be provided for use by the museum, visitor attraction, court buildings, temporary attractions, and nearby shops. Especially as improvements to the area will attract more people by cycle than current levels.

3.2 Accessible cycle parking

No mention is made of the amount of spaces that are accessible, suitable for use by disabled people with adapted cycles. LTN 1/20 (para 11.3.2) recommends that 5% of cycle parking spaces should be made available for this purpose, and the Cycle Campaign recommends a condition is applied requiring this provision.

3.3 Design of parking

The design of cycle parking is not shown however for public use Sheffield type stands should be used. Spacing of racks should be a minimum of 1.0m, and a recommended 1.2m apart, to ensure access by a range of cycles including those with child seats/panniers. Further width should be provided for cargo bikes used by families, and for accessible cycle parking as section 3.2 above. LTN 1/20 table 11-2 should be consulted for the full range of minimum and recommended spacing, and we believe this should be a conditioned requirement.

4. Drawings/Documents Referenced

• Landscape General Arrangement Plans
• Planning Statement
• Transport Statement
• Design & Access Statement