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CPO 2004 Enquiry - Documents Submitted by Bath & North East Somerset Council

Proof of Evidence of Keith Brownlie RIBA on behalf of Bath and North East Somerset Council

Public Inquiry May 2005

Document No: BNES/7/2

CONTENTS

1. PERSONAL INTRODUCTION

2. WlLKlNSON EYRE ARCHITECTS' ROLE

3. DEVELOPMENT OF THE TRANSPORT INTERCHANGE BRIEF

4. THE TRANSPORT INTERCHANGE SITE

5. DESCRIPTION OF THE PROPOSED SCHEME

5.1 Site Strategy

5.2 Station Plaza and Goods Shed Vaults

5.3 The Proposed Bus Station

5.4 The Railway Station

6. OBJECTIONS

6.1 Network Rail

6.2 First Great Western

6.3 First Group PLC

6.4 Rosebys

6.5 Avon Cyclery

1. PERSONAL INTRODUCTION

1.1 I am an equity holding Director of Wilkinson Eyre Architects Limited and have worked at the practice for 14 years. I was educated at the Brighton Polytechnic School of Architecture [BA Hons] and the Mackintosh School of Architecture at the University of Glasgow and Glasgow School of Art [Dip Arch]. I am a Registered Architect and a member of the Royal Institute of British Architects.

1.2 Wilkinson Eyre Architects was formed in 1983 as Chris Wilkinson Architects and incorporated as Wilkinson Eyre Architects in 1999. The practice employs approximately 80 staff in London. It has completed a wide range of projects nationally and internationally including a considerable number of infrastructure and transportation projects and works within historic and sensitive environments. The practice has an excellent reputation for design and has won the Stirling Prize for Architecture twice. in 2001 and 2002 for the Magna Project in Rotherham and the Gateshead Millennium Bridge in Tyneside respectively.

1.3 I have been involved in a number of transport related proposals associated with retail/mixed use developments in UK city centres: including designs for the Bristol Broadmead, Exeter Princesshay, Hull Ferensway, and Liverpool Paradise Street Developments

1.4 My role within the Scheme began at the end of 2000, when Wilkinson Eyre Architects were instructed by Morley Fund Management to undertake the Transport lnterchange design.

1.5 In my evidence I have adopted the abbreviations and definitions set out in the Glossary of Key Terms submitted as CD 10.9.

2. WlLKlNSON EYRE ARCHITECTS' ROLE

2.1 Chapman Taylor LLP are rnasterplanners and Architects for the mixed-use retail and residential element of the proposal located to the north of Dorchester Street.  Chapman Taylor's role is described in the evidence of Mr Carran.

2.2 Wilkinson Eyre Architects are designers and lead consultants for the Transport lnterchange at Bath Southgate, located to the South of Dorchester Street. The proposal incorporates a replacement of the Existing Bath Bus Station, the realignment of Dorchester Street, new on-street bus stops. material alterations to and improvements to the setting of the Railway Station, public realm improvements and associated facilities.

2.3 Wilkinson Eyre Architects were appointed in December 2000 subsequent to the interview of architectural practices with direct relevant experience in the design of transport interchange projects. The planning history of the project, much of which predates Wilkinson Eyre Architects' involvement: is summarised in the evidence of Mr Guy. The design of the Transport lnterchange had been considered problematic In prior submissions. It was felt that the planning history and complex constraints surrounding this element of the project required a fresh approach by an independent practice focused upon the Transport Interchange. In the June 2000 proposal by Chaprnan Taylor the strategic intent had been established for the Proposed Bus Station to be developed in a contemporary design language and it was considered appropriate that the task of providing a modern transport facility in a modern idiom would be progressed by a practice with suitable credentials.

2.4 Dorchester Street is the boundary between the proposals of Wilkinson Eyre, to the south, and Chapman Taylor: to the north. The proposals are configured to provide safe and legible movement across the site and the two practices have worked, with the other members of the consultant team who are common to both elements of the project: together on the configuration of Dorchester Street and its influence on their respective sites. An important element in providing cohesion across the Scheme is the landscape design which has been developed site wide by Livingston Eyre Associates with a commonality of architectural language in the public realm.

2.5 In addition to a collaborative process with Chapman Taylor and the consultant team Wilkinson Eyre developed the design with regard to the advice and commentary of Sir William Whitfield, the Council's consultant architectural and townscape advisor for the Scheme. His influence through the design and consents process informed both the townscape qualities. form and detail of the proposals.

2.6 This Proof of Evidence explains the process of site selection, design and architectural treatment of the Transport lnterchange developed to provide a facility compatible with the Council's regeneration objectives and befitting an important site within the unique built environment of Bath.

3. DEVELOPMENT OF THE TRANSPORT INTERCHANGE BRIEF

3.1 The central aim of the Transport Interchange is the replacement of the substandard Existing Bus Station with the objective of facilitating multi-modal transport within a single high quality environment. It aims to realise the Government's vision for the future of public transport set out in a range of documents including the White Papers: Urban Policy And A New Deal for Transport: Better For Everyone, the consultation paper on bus services: From Workhorse to Thoroughbred: A Better Role for Bus Travel. and PPG 13, Transport.

3.2 'A New Deal for Transport: Better For Everyone' is a United Kingdom White Paper that sets out a new approach to transport policy and embodies modern thinking on integrating transport with other aspects of Government policy. It states that the way forward is through an integrated transport policy including 'integration within and between different types of transport so that each contributes its full potential and people can move easily between them'.

3.3 'From Workhorse to Thoroughbred: A Better Role for Bus Travel' outlines policies that provide the framework for integrating buses with other transport: rail, metro, coaches and airports. They place a new emphasis on quality transport to meet the needs of travellers and the environment. They "demonstrate the Government's commitment to improve mobility and enhance the quality of life for all."

3.4 'PPG 13: Transport' provides guidance with the objective of integrating planning and transport at the national, regional, strategic and local level to promote sustainable transport choices, promote accessibility to jobs, shopping, leisure facilities and services by public transport, and reduce the need to travel, especially by car. It advises local authorities how to deliver its objectives when preparing development plans and considering planning applications.

3.5 Prior to Wilkinson Eyre Architect's appointment to the project the proposals had developed to a stage that envisaged the replacement of the Bath bus station to the former electricity generating site on Dorchester Street between the Railway Station and St James Parade. See Paragraph 4.7 for a description of the site. The foregoing proposals served to highlight issues of concern to the Council and third parties including the competing requirements of providing unencumbered connectivity between the Railway Station and the Proposed Bus Station, and the preservation of the listed goods shed ramp and vaults situated between the two facilities. This may be summarised as being the opposing stances of the Council promoting connectivity and thus removal or alteration of listed fabric on the one hand. and of English Heritage for its retention and preservation on the other.

3.6 A series of objectives encompassing the views of a wide range of parties including the Council and English Heritage were identified by Wilkinson Eyre as guidance to the design process. A list encompassing principal objectives: site planning,  transportation, pedestrian, heritage and architectural issues is included in section 1.2 of the Core Document 11.2 Bath Spa Transport Interchange and Environs Application for Listed Building Consent and Related Applications for Planning Permission and Conservation Area Consent- Supporting Statement Relating to Proposed Alterations to Listed Structures June 2007 [Wilkinson Eyre Architects]. It should be noted that this document sets out site analysis and corresponding design principles but does not represent the approved scheme. The document was not subsequently updated but remains valid in generic content.

3.7 Wilkinson Eyre Architects' initial instruction was to review the fundamental assumptions of the interchange concept and the location of the Proposed Bus Station. This broad ranging remit allowed Wilkinson Eyre Architects to consider the project from first principles and assess the adequacy. desirability and viability of alternative locations the number of which, within the constraints of a sensitive existing urban setting is clearly limited.

3.8 Alternative sites were tested against a series of key criteria to establish the potential of each to fulfil the objectives of the project. (See section 2.1 of the Core Document 11.2). These criteria were as follows:

3.8.1 Proximity to Railway

The proposal should not significantly worsen and should generally improve on pedestrian travel distance between The Railway Station and the Existing Bus Station. Visual as well as physical connectivity is required for clarity of interchange

3.8.2 Severance between Transport Modes

Convenient at-grade pedestrian flow between the Railway Station and the Proposed Bus Station is essential to facilitate seamless connection. In addition, good visual connectivity is required. It is desirable that the interchange has a singular or cohesive identity to visually promote "seamless journeys".

3.8.3 Urban Density

A bus station of the required capacity requires a substantial area of open ground to accommodate bus movements. This represents a potentially major breakdown of urban density and could result in an inappropriate 'rift' in the grain of the City.

3.8.4 Land use

Consideration must be given to the suitability of land-use. The Railway Station and its immediate locale covers an extensive area of established transportation use including multi-modal interchange. The area to the north is well established as a commercial city centre. The area to the west of the Railway Station has historically accommodated industrial uses. Changes to historic street patterns would potentially be necessary.

3.8.5 Effect on bus circulation

The Proposed Bus Station must act as a gyratory to buses not stopping in the station and provide the required number of on-street bus stops for buses that have turned around within the bus station. This latter point is critical is determining the viability of alternative sites because the Dorchester Street area marks the last and first pick up points of many City bus routes and is thus pivotal to bus movement in Bath.

3.8.6 Gateway Potential

A key objective is the need to produce a suitable gateway into the City of Bath. A key component of this is the creation of suitable public pedestrian space and the effective control of passenger movements between the Interchange and the City.

3.8.7 PPG 15 Requirements

The Scheme's effect on listed buildings and the historic environment must be justifiable against the requirements of PPG 15 aimed at the preservation and enhancement of the historic built environment. Of particular relevance are the setting of the Railway Station and impact on the former goods shed site described in paragraph 4.6.

3.9 Consideration of the above criteria, particularly the first two, severely limited the potential area within which a new bus station might suitably be located. Comparative analysis of the alternative sites concluded that only the former electricity generating site described in paragraph 4.7 could reasonably and feasibly fulfil the complex requirements of a new transport interchange for Bath.

4. THE TRANSPORT INTERCHANGE SITE

4.1 The Transport Interchange site includes the Railway Station, described in paragraph 4.6 its northern and southern forecourts, the down-platform car park, the former goods shed site described in paragraph 4.6. and the former electricity generating site, described In paragraph 4.7

4.2 A number of neighbouring places. streets, buildings and structures have a direct bearing on the site and its development as described below:

4.3 Manvers Street

Manvers Street is historically the primary route into Bath for railway passengers. Its orientation influences the front facade of the Railway Station which is skewed in relation to the railway so as to be perpendicular to Manvers Street. The Argyll Building and the Royal Hotel flank the southern end of Manvers street facing the Railway Station and combine with the station itself to form a triptych at the Manvers street/Dorchester Street Junction. The Argyll building is important in dictating the 'building-line' of the west side of Manvers Street and the north side of Dorchester Street.

4.4 Dorchester Street

Dorchester Street is composed of buildings and structures of disparate age, scale, style and quality. It lacks cohesion and marks the end of the urban grain of the city to the north, giving way to pragmatic planning driven by historic patterns of use. A poor quality public realm provides an unattractive entry point to Bath for visitors arriving via the Railway Station.

4.5 Bath Spa Station

Bath Spa Station [formerly Bath Station] opened in 1841. The Great West Railway and the Railway Station itself were constructed to the designs of lsambard Kingdom Brunel who avoided cutting through the Georgian city by taking a line that curved around the south of the centre. Being located so close to the river, the land is substantially lower than that of the town and its approach and the Railway Station itself is elevated on a long viaduct.

4.5.1 The original Railway Station frontage survives. The building was substantially altered in the 1890s and in the twentieth century, most visibly by demolitions and extensions in cl897. This included the removal of the goods shed described below, and the addition of accommodation at the northwest and southwest corners of the 1841 station, as well as a modest extension on the southeast corner to accommodate a parcels lift In the twentieth century single storey extensions were built to the southeast [Avon Valley Cycles] and northwest [Lemon Tree Cafe] of the 1841 building. The entire station development is Grade 2' listed. The goods shed site, described in paragraph 4.6, is listed by virtue of its inclusion within the curtilage of the station. The primary Brunel parts of the station [l8411 are of a high significance, the late 19th century additions are generally of moderate significance and the 20th century structures are considered to be of low significance.

4.5.2 As the station was slightly detached from the main city centre the area immediately to the west and north of the station was also laid out with Manvers Street and Dorchester Street extending west and north from the station forecourt. The streets were intended to be grand avenues linking to the city centre but economic decline resulted in the area being developed in an ad hoc manner with little harmony.

4.5.3 In the current situation the Railway Station accommodates vehicular movement on all sides, and suffers from parking and traffic congestion at its northern forecourt as Mr Hunter Yates' evidence explains. Its pedestrian entrance is in close proximity to the busy Manvers Street/Dorchester Street junction and in general the environment is not pedestrian friendly and is not a fitting gateway to Bath's status as a World Heritage City. The environment of the station as a whole lacks cohesion and quality, and there is little or no ease of connection to the current bus station.

4.6 The Former Goods Shed Site

To the immediate west of the station building the former goods shed site is currently in use as the up-platform carpark. accessed via a 'hair-pin' ramp.

4.6.1 In the 19th century major stations generally had a goods shed for the transfer of freight from train to road consisting of banks or platforms at track level to which carts or other vehicles could be backed-up for loading with goods, or to be loaded onto wagons. At Bath [Spa] Station the goods shed, which was constructed at the same time as the station, was at the same raised level as the tracks, built on a series of stone vaults extended from the railway viaduct. A curved earth ramp was constructed at least in part to allow private carriages to gain access to the platform for loading onto trains. In this respect the station could be considered to always have been, to some extent, an integrated transport interchange. Goods [eg coal] entering the shed on rail wagons would be dropped down from the wagons through hoppers into the vaults below or transferred onto carriages gaining access via the ramp. Whilst the goods shed itself was demolished in 1897. plans from 1932 describing the track layout [including turntables and spurs] on the goods shed site suggest it may have maintained this function well into the 20th century.

4.6.2 In its current surviving form the goods shed site comprises a series of large interconnected stone vaults extend northwards from the railway viaduct. They are not visible from the north and are a hidden part of the station. To the west of the main vaults a series of smaller vaults extend as far north as Dorchester Street. For the purposes of the project these are referred to as the 'finger vaults'. The earth ramp that gives access to the main vaults roof is contained by the main vaults and finger vaults, a retaining wall to Dorchester Street and an earth embankment facing the Railway Station.

4.6.3 The vaults and ramp are integral elements of the Railway Station and locally significant features that provide strong evidence of how the original railway station operated. In the wider context these are common features of the Great Western Railway, and allow comparison with other goods stations along the line.

4.7 The Former Electricity Generating Site

4.7.1 To the west of the former goods shed site lies a collection of buildings and land forming the southern edge of Dorchester Street. In the last decade of the nineteenth century the Bath Electric Lighting Company was established at the converted Kingston Flour Mills to the immediate west of Bath Station goods shed. As the demand for electricity increased, the Dorchester Street Electricity Works was expanded to incorporate the entire block between Dorchester Street and the River, west to Southgate Street [now St. James Parade]. The expansion of the works with a variety of plant housings, administrative and public showrooms reached its peak and effective completion around 1932 with the building of offices and showrooms on the corner of Southgate Street and Dorchester Street.

4.7.2 This building, known as Churchill House, is by the Bath Architect W.A. Williarns and abuts a 1924 block fronting Dorchester Street. presumed to be by the same architect. The building is primarily composed of a three storey commercial property in five bays, clad in bath stone with paired pilasters and decorative horizontal banding, and extensive shop front glazing to the primary street facades at ground level. The building is not listed. Its architecture is representative of a common 'Municipal Georgian' revivalist style of the period. The block performs an important townscape role in providing the 'closure' to key views which is so characteristic of street vistas in Bath: These include the view down Southgate which since 1841 had been formally terminated by Brunel's castellated gothic railway with views carried across the Avon by 'The Old Bridge', which existed online with Southgate to the west of the current Southgate Footbridge. The imposition of Churchill House in c l 933 into the Southgate vista and the removal of the Old Bridge reduced the effectiveness of the established composition and in the current configuration the rounded corner of Churchill House gives focus to views down Southgate rather than the viaduct which is still visible beyond. The building also presents a formal frontage to the river, subsequently capitalised on by the placement of the 'new' Southgate footbridge central to its primary southern facade. The extension of the building eastwards along Dorchester Street acts to provide a street edge and in part terminates views along St James Parade.

4.7.3 Churchill House is effectively a stand-alone building that is one of number of disparate buildings and structures that make up the south side of Dorchester Street. Whilst it is of some visual merit it is isolated and does not form part of an effective and cohesive streetscape.

4.7.4 Wilkinson Eyre Architects' site analysis and detailed design development have established that in order to utilise the former electricity generating site for a replacement bus station, the complete demolition of Churchill House is a necessity for location of the Proposed Bus Station and to realise the Scheme. The Proposed Bus Station has been designed to take cognisance of and perform the same key townscape properties of Churchill House

4.7.5 Also surviving on the former electricity generating site are the remains of the turbine hall. which was built in stages between 1903 and 1930. In the 1960's the Dorchester Street generating station ceased operation and the plant was removed. The building is used at present for car parking, as is the majority of the remainder of the site. In 1969 the site of the original Bath Electric Lighting Company generators was cleared to make way for a new switch house and transformers, which remain.

4.8 WPD Electricity sub-station

An existing high voltage sub-station is located to the immediate west of the goods shed 'finger' vaults. The high voltage distribution network enters this area of Bath across the River Avon and into Dorchester Street. Electricity for a large part of the city centre is supplied from this location.

4.9 River Avon

The River Avon marks the southern boundary of the Transport Interchange site. The Environment Agency have a responsibility for maintenance of the quay walls and consequent access rights.

4.10 Avon Railway Bridge [Skew Bridge]

The bridge is a grade 2 listed structure bearing on central piers in the river plus abutments behind the south quayside promenade and directly on the quay edge to the north. The bridge has significant [probably retro-fitted] structural ties penetrating deep into the goods shed station vaults for which maintenance access is required.

4.1 1 Southgate Footbridge

The footbridge connects the River Avon Southside Towpath to the south west side of the former electricity generating site

4.12 Southgate

The line of Southgate as a primary north-south route and visual axis is historically established, although somewhat diluted by the current road alignment, and the later imposition of Churchill House which nonetheless acts as a visual focus at its southern end.

5. THE PROPOSAL

5.1 Site Strategy

The basic concept of this part of the Transport lnterchange is to locate the rail and bus stations to either side of a new public plaza that is designed to provide clarity and convenience for passengers, and a suitably civic arrival point to the City. Through consolidation of the transportation uses on a continuous and contained site, the design provides a legible focus for movement into and around the city and a defined southern edge to the commercial centre.

5.1.l The relationship between pedestrians and vehicles is a key focus of the proposals, which are configured to separate them wherever possible and to control their interaction where it is not. The new plaza is central to this strategy, allowing the south side of Dorchester Street to be entirely in the pedestrian public realm, with a single vehicular crossover.

5.2 Station Plaza and Goods Shed Vaults

The station plaza is proposed on the site of the listed former goods shed ramp, requiring demolition of and alterations to listed fabric. This is a central tenet of the design and offers clear benefits to both the successful functioning of the Transport lnterchange and its integration into the Scheme and the City.

5.2.1 The proposal removes the earth ramp and its retaining walls and embankments. It retains all of the main vaults and finger vaults. The end walls of the stone vaults will be unblocked and glazed, and for the first time the public will be given views and access to these spectacular spaces which will be refurbished and let for retail uses. Other vaults will incorporate Transport lnterchange passenger facilities including WC's and left luggage.

5.2.2 The demolition of listed fabric is justified on a number of counts. as it allows the development of a cohesive multi-modal transport facility and a high quality new public place at a major point of access to an historic city. improves the setting of the listed station. aids public understanding of and engagement with a hidden heritage resource, and protects the main element of the listed structure through restoration and viable reuse

5.2.3 The plaza that will occupy the space vacated by the ramp will be lined on three sides by 'live frontage' and open on the north to Dorchester Street. Pedestrians will animate the plaza using the on-street bus-stops, interchanging between bus and rail, moving between Transport lnterchange and the Scheme. or taking a north-south route via the Railway Station.

5.2.4 The landscape of the plaza addresses levels and pedestrian 'desire-lines', to account for the needs of both transient users and people using it as a destination. Stone paving, planting, lighting and furniture are combined to provide a high quality environment in combination with a revitalised historic context.

5.2.5 The removal of the ramp takes the up-platform car-park out of commission. In order to avoid this area at track level becoming moribund, and for compositional and commercial reasons, a new single-storey commercial building is proposed on the car park site. It traverses the main goods shed vaults and 'caps' the vaulted facade to the plaza, with access gained from the lower level via a stone and glass clad 'external' core.

5.3 The Proposed Bus Station

The Proposed Bus Station has been designed in close collaboration with First, the principal operator, as well as the Council. The design provides like-for-like replacement of facilities and in many respects provides betterment including the provision of a fully enclosed passenger concourse. From a health and safety perspective the proposal provides a layout that greatly reduces the potential incidence of pedestrian ingress into the bus compound, which is a basic tenet of bus station safety and a primary failing in the current facility.

5.3.1 The Proposed Bus Station comprises passenger and operational facilities. 16 bus and coach stands and a further 8 spaces for vehicle layover. The Proposed Bus Station building is the most visible new element of the Transport Interchange, designed in a contemporary manner creating a counterpoint to the historically styled proposals north of Dorchester Street.

5.3.2 The building is laid out along the south side of Dorchester Street, with a double height enclosed passenger concourse separating the street from the vehicle yard to the south. The concourse additionally serves on-street bus stops on Dorchester Street. At the corner of Dorchester Street and St James Parade a rotunda building of 4 storeys houses a passenger ticketing and information centre with bus operator's accommodation above. A further two storey building extends south from the rotunda to 'enclose' the vehicle yard on the west side. Vehicles circulate in an anti-clockwise manner, entering the station from the west on St. James Parade and exiting on the east to Dorchester Street.

5.3.3 The rotunda building is located broadly on the site of Churchill House, its footprint extending north and west of the existing. It is configured to perform the same townscape role as Churchill House outlined in paragraph 4.7.2 . The position of the new building is heavily dictated by the spatial requirements of manoeuvring vehicles to the south and precludes the retention of Churchill House. The design of its replacement delivers a notable and appropriate modern building in an important pivotal location.

5.3.4 The land vacated in the proposal by the current Bath Bus Station is made available for uses that are of a more appropriate urban density and an architectural language that is consistent with the historical character of the City.

5.4 The Railway Station

The functioning and layout of the Railway Station was comprehensively reviewed as part of the design process. The proposals address existing deficiencies by allowing for the relocation of existing uses and changing the permeability and navigation of the station environs by passengers and pedestrians. A new station entrance is proposed to the northwest and the option of reopening the southern entrance facilitated. Pedestrian routes to the east and west of the station building have been retained and improved.

5.4.1 The 1841 original building and its 1897 additions are revealed by the demolition of poor-quality late 20th Century additions to the northwest and south east. The proposed demolition of the goods shed ramp and reconfiguration of the station forecourt will improve the setting of the station and open up new views of the station.

5.4.2 The current saturation of the station perimeter by parked and moving vehicles is addressed through the removal of the current vehicular circulation pattern. All vehicles will both access and exit the southern forecourt and down-platform car park via the east of the station building. Taxis, and service vehicles serving the back of the goods shed vaults and station retail units: will also be constrained to this circulation system. The current conflict of taxis and pick-up/drop -off at the station entrance is removed by relocation of the taxi rank and short stay parking.

5.4 3 The northern forecourt will be easier and safer to navigate for pedestrians, with an enhanced environment in terms of landscape and facilities and legibility in terms of visual and physical connections to the Interchange, Southgate and the City.

5.4.4 The southern forecourt is extensively remodelled with a view to re-establishing the original condition of the station as a dual fronted building. The proposals include the option to re-open the southern entrance and carry out internal reorganisations to allow passengers to move through the station building on a north-south route. A new south canopy will replicate the original provision. The control of vehicular movements and the establishment of a pedestrian only route between the southern forecourt and the plaza to the west of the station building will enhance pedestrian use and safety. Demolitions and reconfiguration of retail units with southerly frontages will make the southern forecourt more useable and less peripheral.

6. OBJECTIONS

6.1 Network Rail

My evidence is indirectly relevant to Network Rail's objection to inclusion in the notice of 'operational property' required for Network Rail's statutory undertaking.

6.1.1 The scheme includes alterations to the Railway Station designed to expedite passenger use of the station and of the Transport Interchange. through modal change. Phasing of the works has been developed to ensure continuity of operation of the railway throughout the process

First Great Western

First Great Western did not cite specific reasons for their objection.

First Group PLC

My evidence is relevant to First Group PLC's objection concerning the design of the replacement bus station. including health and safety. and other operational matters.

6.3.1 The issues surrounding the manoeuvring of buses, particularly within the curtilage of the bus station to the south of the passenger concourse, is dealt with in detail in the evidence of David Hunter Yates.

6.3.2 The scheme has been designed in close collaboration with First. The design provides like-for-like replacement of facilities and in many respects provides betterment. Primary amongst those aspects that provide an improved facility are the provision of a fully enclosed passenger concourse. From a health and safety perspective the proposal provides a layout that greatly reduces the potential incidence of pedestrian ingress into the bus compound, which is a basic tenet of bus station safety and a primary failing in the current facility.

6.4 Rosebys

My evidence is relevant to Rosebys' objection that the Statement of Reasons does not justify how the proposal overcomes earlier criticisms of previous schemes for the Transport Interchange.

6.4.1 My evidence demonstrates that the proposal is the result of independent analysis of the site and objectives of the brief. The scheme has been designed in consultation with the Council, the Council's consultant architectural and townscape advisor, English Heritage and third parties.

6.4.2 The Listed Building Consent is the most significant issue in relation to overcoming earlier criticisms of previous schemes for the Transport Interchange. The replacement of the goods shed ramp with a new civic public space between the Railway Station and the Proposed Bus Station is the most visible change from the foregoing schemes, and overcomes the most critical aspects of them by providing ease of connectivity between transport modes and prioritising pedestrians and passengers within a high quality public realm.

6.5 Avon Cyclery

My evidence is relevant to Avon Cyclery's objection that the notice affects their business.

6.5.1 The proposals include the demolition of the 20th century lean-to addition on the south east corner of Bath Spa Station which forms a shop premises for Avon Cyclery. This is a key element in the architectural rejuvenation of the south side of the station in conjunction with the proposed re-opening of the south side entrance and the rationalisation of traffic movements by removal of the gyratory system.

6.5.2 Whilst Wilkinson Eyre Architects' remit and my evidence does not cover issues of tenancies the proposal includes for a retail unit of comparable size, including the front-of-house element, to The Avon Cyclery at the west side of the station. The proposed unit occupies two vaults at the west side of the station with a frontage to the south in a corresponding relationship to the Railway Station as the existing retail unit on the east. This position is on the revised pedestrian thoroughfare between Widcombe Bridge and the new station plaza. It is envisaged that an increased and controlled footfall and enhanced pedestrian environment will substantially replicate the visibility and viability of the retail operation of the existing eastern shop unit.