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

1 Introduction and Background

1.1 INTRODUCTION

1.1.1 My name is David Hunter-Yeats and I am a Director of WSP Development Limited which is a 350 strong company within the 5000 strong WSP Group, one of the country's leading engineering consultancies for both civil engineering and building services.

1.1.2 I am a Chartered Civil Engineer and am a Member of the lnstitution of Civil Engineers, a Fellow of the lnstitution of Highways and Transportation and a Chartered Member of the Institute of Logistics and Transport.

1.1.3 I hold an Honours degree in Civil and Structural Engineering from the University of Sheffield gained in 1969.

1.1.4 My 36 years professional experience since University has been spent entirely in the field of Highways and Transportation. For the last eighteen years I have been involved in the transport aspects of major development proposals especially town centre retail schemes.

1.1.5 Completed schemes that I have been involved with through this period include the Spindles in Oldham, Churchill Square in Brighton and Whitefriars, Canterbury. I am currently involved with around fifteen town centre retail developments throughout the UK.

1.1.6 I have also served on the Executive Council of the British Parking Association (BPA), sat on the Board of Directors of the Association of Town Centre Management (ATCM), and become a Member of the British Council of Shopping Centres (BCSC). I have taken a special professional interest in car parking and have presented papers at conferences run by BCSC, BPA and ATCM.

1.2 BACKGROUND

1.2.1 My Company has been retained by CGNU since 1996 to provide transport advice for the proposed Southgate re-development. This has included the following work:

• Design of revised road layouts
• Design of the layout of the basement car park and service areas
• Assessment of impact on public transport services
• Design of new bus station
• Assessment of number and location of on-street bus stops
• Traffic Impact Assessment (TIA)

1.2.2 I have been involved personally since 1996 as Director responsible for the project and am instructed by the Council to present the evidence on Transport on their behalf. l have been heavily involved in the formulation of the scheme over the years and especially the design of the replacement bus station.

1.2.3 I have visited the site and surrounding area on many occasions and held meetings with officers of the Council as well as with First Bus, First Great Western and Railtrack/Network Rail.

1.3 CONTENT

1.3.1 In my evidence I have adopted the abbreviations and definitions set out in the Glossary of the Terms submitted as CD10.9.

1.3.2 In my evidence I shall describe briefly the key elements of the Scheme concentrating on those that are transport related. Other witnesses will deal in more detail with the physical works to be undertaken to the buildings and in particular Keith Brownlie regarding the new bus station.

1.3.3 I shall then describe the assessments undertaken through the planning stage with regard to traffic impact, access, servicing arrangements and parking provision.

1.3.4 I shall demonstrate that from a transport viewpoint, the Scheme proposals are not only workable, but appropriate for this city centre location. I shall describe thenecessary highway improvement works which were agreed with the Highway Authority and incorporated in the S106 Agreement. Accordingly I go on to consider that there are no highway impediments to the Scheme proceeding if the Order is confirmed.

1.3.5 The issues raised by objectors include general concerns over the adequacy of the access arrangements, for the various individual occupiers. There have also been concerns raised over the operational aspects of the new bus station and over the adequacy of public car parking spaces.

1.3.6 I shall explain how the transport proposals will operate both during the construction phase and following scheme opening, and demonstrate that all of these concerns nave been fully addressed.

1.3.7 I shall also describe the transport benefits that will flow from the Scheme if the CPO is confirmed so that it can proceed.

1.3.8 The location of the Scheme within Bath is shown on Figure DHYI . The site boundary and existing road network and transport facilities are shown on Figure DHY2.

1.3.9 The transport and highway implications of the Scheme proposals have been considered in several Transport Assessments undertaken by my company, starting with reports in 1997 and 1998 followed by a comprehensive new report incorporated within the 2001 Environmental Statement.

1.3.10 As I will explain later in more detail, the Scheme requires modifications to the existing road network to accommodate the new building footprints. The existing and proposed road networks are shown on my Figure DHY2 and 3.

2 Existing Situation

2.1 INTRODUCTION

2.1.1 Bath City Centre is well served by public transport having a main line railway station, a large bus station and a significant number of bus stops on-street for use by the local bus services. However, the location and standard of these facilities are not of a high enough quality to encourage and promote their use.

2.1.2 In addition I consider that the environment for pedestrians is not conducive to a pleasant walk due to narrow footways and few controlled pedestrian crossings.

2.2 PEDESTRIANS

2.2.1 The railway station has two small car parks for use by passengers which result in a significant amount of car traffic on all sides of the station. This conflicts with the main pedestrian access route across the River Avon from the south (see photo 3). This route is shown by Rodney Carran in his Figures.

2.2.2 In addition the main pedestrian approach to the station entrance involves crossing the station forecourt which is used as a taxi rank, short stay parking area (maximum 20 minutes) and also as a drop-off and a pick-up location for passenger. This area involves significant conflicts for pedestrians either travelling to the station or passing by (see photo 2).

2.2.3 Having arrived at the railway station passengers wishing to reach the City Centre are faced by the heavy traffic using the Manvers Street/Dorchester Street/Newark Street/Railway Street gyratory immediately in front of the railway station. Although there is a pelican crossing to enable them to cross the first corner of this gyratory, pedestrians are then required to negotiate either the vehicular entrance or exit to the existing bus station within this highway gyratory (see photo 14).

2.2.4 There are no signal controlled pedestrian facilities to assist crossing the vehicular entrance/exit and indeed there is only one signalised pedestrian crossing facility connecting the bus station within the gyratory to the remaining pedestrian routes into either the Southgate Centre or the City Centre. This is shown on Figure DHY 2.  Pedestrians therefore tend to cross this highway gyratory without any assistance and in a random fashion leading to difficulties for motorists having to take care to avoid pedestrians crossing in so many different locations.

2.2.5 With the bus station being located within this highway gyratory, all passengers are required to cross one of the four roads forming the gyratory square in order to reach or leave their bus. With the majority of bus passengers seeking to reach the City centre this leads to significant flow of passengers across Railway Street which does not have any signal controlled pedestrian facility unlike Newark Street or Dorchester Street. These bus passengers when added to the railway passengers create a significant pedestrian flow crossing these roads without assistance and protection from conflicts with cars, lorries and buses (see photos 18-20).

2.2.6 Pedestrians wishing to walk along Dorchester Street between the railway station and the Churchill Bridge are required to walk along footways only 2.5 metres wide on which bus stops are located (see photo 7).

2.3 CYCLISTS

2.3.1 Dorchester Street with its significant traffic flow of both general traffic and buses is not friendly to cyclists. The gyratory surrounding the bus station aggravates the situation due to restricted visibility for motorists of cyclists around the corners of the gyratory (see Photo 10). There is also a restriction on cyclists riding along Southgate which is fully pedestrianised.

2.3.2 There are, however, some short lengths of cycle track along the river towpath and along New Orchard St as it crosses Stall St in to Lower Borough Walls (see photo 27)

2.3.3 Currently there are "sheffield" style cycle racks spread around the city centre to enable cycles to be left secure whilst their riders are shopping (see photo 27).

2.4 BUSES

2.4.1 The existing bus station has very limited facilities for passengers especially in relation to weather projection and travel information (see photo 14). As the bus station caters mainly for the out of city and longer distance services, it is usual for passengers to arrive in good time for the departure of their service and therefore the amount of waiting is in general more than at city centre on-street bus stops.

2.4.2 This highlights the inadequacy of the existing waiting facilities and also the limited areas at each bus stand for the waiting passengers to mingle comfortably without too much inconvenience for passengers walking through the bus station concourse.

2.4.3 The on-street bus stops are also not of the appropriate high standard for today's passengers and vehicles. The bus stop locations on the streets around the Southgate Centre are located too close together which results in buses being unable to get into certain stops to disembark alongside the kerb. This leads to the bus arriving having to stop out in the main carriageway in order to disembark and embark passengers thus blocking other traffic including buses.

2.4.4 The footways alongside the on-street bus stops are also limited in width, especially along the southern side of Dorchester Street (see photo 7). This leads to overcrowding at bus stops which affects not only the many passengers alighting and boarding but also those pedestrians wishing to pass by.

2.4.5 The recent switch from 8.5 metre long shuttle buses to the more normal 12 metre long single and double decker buses has aggravated the problem caused by bus stops being too close together. These larger buses are able to carry a significant number of passengers, which leads to longer alighting and boarding times. This aggravates the effect on traffic from double-parked buses.

2.4.6 Currently bus passengers enjoy only limited amounts of weather protection at  onstreet stops (see photo 7) and the bus station. There is no weather protection on the routes between the bus stops and the railway station to improve the environment for those interchanging between travel modes (see photo 6).

2.5 SERVICING

2.5.1 The servicing areas for the existing Southgate Centre are located on the roof of the building with access via a ramp off Kingston Road. The facilities on the roof are limited and are not capable of accommodating a significant number of full length articulated vehicles which are becoming more common amongst major national retailers.

2.5.2 The existing servicing arrangements to the lceland retail unit and also Comet are both less than ideal in view of their location and conflicts in Kingston Road with the exit from the Ham Gardens car park and the Southgate Centre service ramp.

2.5.3 The lceland store has a service entrance requiring the lorry to park in direct conflict with the pedestrian route from Kingston Road through to the Southgate Centre past the public toilets. The delivery vehicle when arriving has to reverse up to the unloading door causing significant pedestrian/vehicle conflict.

2.5.4 The Comet unloading area whilst being located within its private curtilage does conflict with the staff and visitor car park. This reversing manoeuvre through a semi public car park leads to conflicts and inconvenience if motorists wish to arrive or leave while the lorry is unloading as it will be parked blocking the parking spaces.

2.6 PARKING

2.6.1 The shopping area around the existing Southgate Centre is served mainly by two large car parks namely Ham Gardens multi-storey car park (located immediately to the north of the Railway Street gyratory) (see photos 20 & 21 ) and the Avon Street multi-storey and surface car parks (located to the west of Southgate/St James's Parade).

2.6.2 Whilst both locations are conveniently close to the shops and tourist attractions in Bath, neither car park is of a high quality. The arrangements and layout are not easy for motorists, being split-level configuration with multiple short ramps which are narrow by modern standards.

2.6.3 Also the pedestrian routes to and from the parked vehicle are awkward with the steep ramps between half decks and the less than pleasant stairways. This "split level" configuration is not helpful for those with pushchairs or in wheelchairs due to the multitude of level changes.

2.6.4 The Avon Street car parks are located within a highway gyratory. Motorists are therefore required to cross a busy road to reach all destinations without any pedestrian crossing facilities.

2.6.5 There are parking spaces for those motorists with "blue badges" on New Orchard St and on many of the other smaller city centre streets. These are convenient for the shops which are well spread out in the city centre.

2.6.6 The Ham Gardens multi-storey car park which is within the site for the Scheme also provides some spaces for blue badge holders. These are conveniently located but do require the passengers to negotiate the many stairs of this split level car park or use the lifts. The lifts serve only the parking levels 2, 4, 6, 8 on the southern half of the car park.

3 Scheme Evolution

3. l INTRODUCTION

3.1.1 The Southgate Centre was owned by the Prudential prior to its acquisition by CGNU and Shearer Property Group in 1995. The Prudential spent some considerable time investigating options for redeveloping the Centre and in 1988 they submitted a planning application (7741-43). This planning application was, I understand, for a large single building enclosed shopping centre which the Council did not consider complied with its objectives.

3.1.2 In February 1996 my company, then known as Frank Graham Consulting Engineers, were appointed as Transport Consultants by CGNU.

3.2 EVOLUTION

3.2.1 We joined the rest of the design team in commencing the long process of investigating the Scheme site and beginning to formulate development options in consultation with Officers of the Council. The results of these studies are included in Core Document CD10.7 dated April 1997, entitled "Review of Evaluation of Outline Proposals (Chapman Taylor).

3.2.2 Notwithstanding the exhaustive investigation at this preliminary stage further work was undertaken over the following five years in reviewing, adjusting and improving not only the location of the bus station but also its layout, configuration and passenger facilities.

3.2.3 A key component of the Scheme was to improve the quality of the public transport interchange, i.e. to help passengers to move between the bus station, on-street bus stops and the railway station, and for this to be as seamless as possible.

3.2.4 The Scheme, as originally configured in 1997, located the new bus station to the north of Dorchester St, close to its existing location. All subsequent configurations located the bus station to the south. This relocation greatly improved its connectivity with the railway station and the bus stop along Dorchester St.

3.2.5 The bus station layout was changed in successive substituted drawings to improve  interchange with the railway station and to improve the operation of layover, drop-off and embarkation stands. The Scheme substitutions occurred in October 1998, October 1999, June 2000 and lastly June 2001.

3.2.6 The location of Brunel's railway vaults and especially the "Finger" vault eventually defined the eastern-most boundary of the proposed bus station as their demolition was considered unacceptable. Following that decision, the later changes to the bus station have been to improve the passenger concourse and other associated facilities.

3.2.7 Rodney Carran shows the various stages of the Scheme evolution in a combined drawing within his Figures whilst Keith Brownlie describes the bus station evolution in detail.

4 The Scheme

4.1 INTRODUCTION

4.1.1 The Planning Consents comprise city centre redevelopment of major comparison and some convenience retailing floor space, leisure facilities and residential units. It also contains significant new transport facilities including a high quality bus station, 724 car parking spaces and two service yards, one below ground.

4.1.2 Other Witnesses deal with the non-transport facilities whilst I concentrate solely on those areas for which I have been personally involved in formulating the Scheme proposals in conjuction with both Rodney Carran on the retail areas and Keith Brownlie on the transport interchange.

4.2 PEDESTRIANS

4.2.1 An investigation was undertaken by my company as part of the June 2001 Transport Assessment into the usage of facilities by pedestrians and to identify the best locations for additional controlled crossing facilities.

4.2.2 As part of the modifications to the highway network, additional signal controlled pedestrian crossing facilities will be incorporated in St James's Parade, Dorchester Street and Manvers Street. These have been deemed by the Council as adequate to cater for the future flows that will be passing between the proposed bus station and the existing railway station and the City Centre.

4.3 CYCLES

4.3.1 The Scheme will provide 80 racks for cycles in locations throughout the area convenient for arrival from the new highway network and for reaching the shops beyond on foot.

4.3.2 There is provision by means of a f 10,000 financial contribution within the S106 Agreement for the Council to provide additional cycle racks.

4.4 MOBILITY IMPAIRED ACCESS

4.4.1 The mobility impaired visitor whether travelling on foot, in a wheelchair or by car does sometimes require special treatment to assist them with their visit.

4.4.2 The proposed new car park will have about 32 disabled persons' spaces marked out for their exclusive use on the upper car park level. These will be the standard 3.6m wide bays, i.e. 1 % bay widths and marked with the usual disabled symbol and hatching. These spaces will be adjacent to passenger lifts which will give access to all public levels.

4.4.3 The Shopmobility Centre which is currently located in Railway Street will be relocated to the north side of the department store opposite Kingston Road, close to the main lift core.

4.4.4 The Southgate area is free of steep gradients and therefore all parts of the development will be accessible to disabled people once they have reached the area. Those that arrive by bus will be able to travel from the bus station into the scheme using signalised crossings on Dorchester Street. Those travelling by city bus will have to cross Dorchester Street only once on either their arriving or departing journey. They will be able to make use of the signal controlled pedestrian crossings.

4.4.5 The replacement of the unfriendly split level Ham Gardens car park by the 3 level flat deck parking will be of major benefit to the mobility impaired visitor. The relocation of the bus station from within the road gyratory of Newark Street/Railway Street/Manvers Street, will remove the current access difficulties of the bus station from the city centre. This will be true whether they are visiting our shopping buildings, the leisure units or just the adjacent city centre.

4.5 BUSES

4.5.1 The new bus station is to be located alongside the railway station on the southern side of Dorchester Street with the River Avon to the rear. The bus station will incorporate the same "nose-in" stopping arrangement as the existing bus station and will maintain the existing 16 bus stands with two reserved for the long distance national express coaches.

4.5.2 The pedestrian waiting areas will be significantly enhanced within a glass walled building which will incorporate up to date bus arrival and departure information.

4.5.3 The location and configuration of the bus station with the river to its rear, will remove the current problem of pedestrians wandering across the open bus manoeuvring areas at significant personal risk of being hit by reversing buses.

4.5.4 The bus station layout and number of bays was agreed several years ago with First Bus (Badger Line) with the bay width slightly greater than those existing and also to cater for the then maximum length bus of 12 metres. At that time First Bus was running mainly 9 metre buses. They anticipated moving to 12 metres in the future and this was taken into account with the proposed layout.

4.5.5 The proposed bus station waiting enclosure abuts the southern footway of Dorchester Street. Along this section of footway, there are four bus stops for city buses thus providing excellent interchange facilities with the longer distance buses in the bus station. (See Figure DHY 3).

4.5.6 There are a further three bus stops on the southern footways of Dorchester Street from which bus passengers can walk to the proposed bus station without having to cross the heavily trafficked Dorchester Street.

4.5.7 Passengers from all these seven bus stops can also walk in greater safety to the Railway Station with only the signal controlled exit from the bus station to cross.

4.5.8 The relocation of the existing bus station permits an enhancement and enlargement of the retail area. However, this change necessities making Dorchester Street two way through to its junction with Manvers Street by the railway station. This new highway layout is shown on my Figure DHY 3.

4.5.9 The revisions to the highway network enabled a re-planning of the on-street bus stops and these are also shown on my Figure DHY 3. These locations were discussed and agreed with First Bus and the Council.

4.5.10 Although the number of on-street stops has remained as before, they have been lengthened to accommodate 12 metre buses and they have been moved further apart to enable buses to access and depart from each bay while adjacent bays are also occupied. This is a significant improvement on the current arrangement which force buses to double-park to disembark and embark their passengers.

4.5.11 I therefore consider that the Scheme will result in a significant improvement in facilities for buses and their passengers both in the proposed bus station and also at the on-street stops.

4.6 SERVICING

4.6.1 The other main transport facility being provided is off-street servicing capable of accommodating the peak number of delivery vehicles and also the maximum sizes now permitted i.e. 11 metre long rigid lorries and 16.5 metre long articulated lorries.

4.6.2 There are two service yards in the Scheme both accessed via Henry Street and Kingston Road as shown on my Figure DHY 3. The first yard is located at ground level immediately to the rear of Ham Gardens and the existing Iceland retail unit which will be serviced from this location (see Figure DHY 14). The second yard is located underground beneath the main retail scheme and accessed via a two way ramp located on Kingston Road immediately to the south of the other smaller delivery area (see figure DHY 16).

4.6.3 The underground service yard will have sufficient bays to cater for the new department store and also the retail units fronting Dorchester Street and Southgate.  This facility will also deal with the removal of waste material, thus obviating the need for any delivery vehicle to be present within the planned pedestrian street contained within the retail area.

4.6.4 Half of these delivery bays have been designed for access by 16.5 metre articulated lorries and half limited to 11 metre rigid. Research published by BCSC (British Council of Shopping Centres) has shown that only 8% of deliveries are made by articulated lorries.

4.6.5 Accordingly, this inability for all bays to accommodate 16.5 metre lorries is not an operational problem and the delivery areas have been accepted by the Council.

4.7 PARKING

4.7.1 The Scheme will include 724 parking spaces in a three level basement (See Figures DHY 9-1 l ) with its access taken from a signal controlled access close by the signal controlled junction of St James's Parade with Dorchester Street. There will be around 30 spaces marked and reserved on level -1 for use by the disabled ("blue badge" holders) whether drivers or passengers.

4.7.2 Within the 724 spaces there will be a reserved area on level -3 of around 130 spaces for the use of railway passengers parking their cars in order to travel onwards by train. This railway parking provision is to permit the removal of the railway station west car park located on the Brunel ramp and above the Brunel Vaults.

4.7.3 The Scheme will result in a loss of 95 public parking spaces in the Southgate area due to the demolition of the 654 space Ham Gardens multi-storey car park as well as the 100 space railway station (West) car park mentioned above and the loss of the 65 spaces parked on the former SWEB office car park where the new bus station is to be located. These 819 spaces are replaced by the 724 spaces within the Scheme.

4.7.4 However, this slight loss in overall public parking has been agreed with the Council following detailed parking analysis and assessment of the overall availability for shoppers within the city core of circa 4,000 spaces. The city are also planning future expansion of Park and Ride including a new site to the East at Lambridge.

4.8 HIGHWAYS

4.8.1 The impact of the proposed development on the existing and proposed highway network has been analysed several times over the lifetime of this application with reports in 1997, 1998 and 2001. Each of these studies and their associated reports were discussed and agreed in detail with the Highway Authority subject to the signalisation of the Churchill gyratory as shown in my Figure DHY 5 and also a financial contribution to enable the Council to undertake a minor junction improvement at the Bathwick Street/Beckford Road Junction (see Figure DHY 6).

5 S106 Obligations Of The 2003 Consent (Ref 01/01019/FUL)

5.1.1 As I have already mentioned the Scheme will bring some significant improvements to the transport facilities in this part of the City. These include improvements to the Highway Network, bus stops and passenger facilities. The S106 Agreement defines these improvements but also sets out some constraints on the phasing of the construction in order to minimise or avoid disbenefits during the construction while the existing facilities are being upgraded.

5.2 HIGHWAYS

5.2.1 The Highway benefits include full signalisation of the Churchhill Gyratory in order to improve the operation of what is now an elongated roundabout and which suffers from peak hour queues.

5.2.2 A minor improvement at the Bathwick Street junction will avoid a potential congestion overload due to the Scheme traffic by replacing the existing roundabout with traffic signal control. This will also include pedestrian crossing facilities at the junction.

5.2.3 A further change to the existing highway network involves the introduction of bus priority Ambury in the northbound direction. This not only provides bus priority and encouragement for that mode of travel but also ensures that all arriving shoppers travelling by car have to pass the Avon Street car park and therefore have the opportunity to park there before reaching the Scheme car park with its smaller capacity.

5.2.4 The S106 Agreement requires the provision of two remote VMS (variable message signage) signs on the public highway giving advance notice of space availability in the Avon Street and Scheme car parks.

5.3 CONSTRUCTION PHASING

5.3.1 In view of the extensive changes to the bus facilities proposed, the S106 Agreement requires that the same number of stops both on-street and within the bus station are maintained in reasonably close proximity to their current location throughout the construction period.

5.3.2 The re-alignment of Dorchester St and the new bus station takes place during the first phase of the Scheme. Accordingly the new road network and many of the new bus stops will be operational before the main site construction commences. I am therefore satisfied that an appropriate arrangement of permanent and temporary bus stops will be identified to satisfy this requirement.

5.3.3 The S106 Agreement also requires that the existing traffic flows are maintained in so far as reasonably practical "throughout the construction period". With the new Dorchester St being the first part of the Scheme to be constructed, I do not envisage difficulty in complying with this traffic flow requirement.

5.3.4 It also necessary for the developer to maintain existing pedestrian routes so as not to disadvantage pedestrians travelling between the City Centre and the railway station/bus station and on-street bus stops. The existing pedestrian routes and the existing flows are shown on my Figures DHY 7 and 8. With the new Dorchester St being the first part of the scheme to be constructed, I do not envisage difficulty in complying with this pedestrian flow requirement.

5.4 PROPOSED BUS STATION

5.4.1 The developer is required to prepare a management plan for the new bus station and for this to be agreed with the Local Planning Authority.

5.4.2 In addition a route through the bus station for non-terminating buses wishing to "turn around" has to be provided along the rear of the bus station area and act as a "drive through" facility. This is to replace the existing highway gyratory around the current bus station. The proposed bus station as shown in my Figures DHY 3 and 4 has this through route as part of the Scheme. Accordingly the obligation is being complied with.

6 Transport Policy

6.1 INTRODUCTION

6.1.1 The issue of compliance with Local and Central Government Policies on transport was discussed in the Transport Assessment published in November 1997, the Revised Transport Assessment of 1998 and the 2001 Environmental Statement which incorporated an updated Transport Assessment.

6.1.2 These reports dealt with policies which encourage non-car movement and seek to minimise the length and growth in motorised journeys and reduce the need to travel, especially by car. The reports also dealt with the proposed parking provision and its compliance with the policies to minimise parking provision and hence private car usage.

6.1.3 The relevant transport policies that relate to this development can be found in national guidance PPG 13, PPS6, Bath Local Plan (adopted 1997), the Bath and North East Somerset Local Plan Deposit Draft January 2002 and the Bath and North East Somerset Local Transport Plan.

6.2 PPGI3

6.2.1 PPG13 provides advice on integrating transport and land use planning in order to

• promote more sustainable transport choices and
• reduce the need to travel especially by car.

6.2.2 This reflects the national policy for sustainable development, the principal aim being to reduce reliance on the car by encouraging more efficient journeys and alternative means of transport. Therefore the focus of PPG13 is upon influencing location and form of development to achieve these objectives.

6.2.3 There is also guidance on the need to provide adequate short stay shopper car parking so as to maintain the vitality and viability of the town centre. The Southgate Centre development complies fully with PPGI 3 in so far that it is located within the central retail core and is located at a major Public Transport interchange.

6.2.4 This interchange consists of the railway station and a new modern high quality bus station as well as a significant number of improved on- street bus stops serving the city bus routes.

6.2.5 All three of these travel modes are integrated on Dorchester Street and provide easy passenger movement between all of them.

6.2.6 To assist passengers moving not only between the various transport modes but also to the City Centre, additional signal control pedestrian crossing are provided along Dorchester Street to assist all passengers and pedestrians (especially those with disabilities) to cross this busy road in safety.

6.2.7 PPG 13 also discusses the appropriate levels of car parking to be provided in the city centre and how the availability of car parking has a major influence on the means of transport people choose for their journeys (para 49). It speaks of the need to minimise the amount of parking in new developments as part of a package of planning and transport measures to promote sustainable travel choices.

6.2.8 The Scheme with its 724 spaces complies with this objective as the proposed parking is less than the existing parking.

6.2.9 Parking spaces lost include the 654 spaces within the Ham Garden Multi-storey car park, the 100 spaces in the West Car Park at the railway station and also the 65 spaces in the public car park to the rear of Churchill House (formerly the SWEB office car park).

6.2.10 In conclusion I consider the Scheme complies with the objectives of PPGI 3.

6.3 PPS 6

6.3.1 The location of the Southgate development with its excellent accessibility by car, bus and train as well as from adjacent residential areas by foot shows that it complies with the Government's second key objective as set out in its paragraph 1.3 "by focusing development in such centres ... accessible to all.

6.3.2 Paragraph 1.4 sets out the Government's objective to improve accessibility by ensuring that the Scheme is well served by a choice of means of transport. As I have already stated the Scheme is located in close proximity to the proposed bus station, the railway station and all of the on-street bus stops. It therefore complies excellently with these key Government objectives.

6.3.3 The proposed revisions to the highway network which remove the busy road network surrounding the existing bus station and replace it with a series of pedestrianised streets confirms the Schemes compliance with the objectives of its paragraph 2.6 "to allow easy access on foot".

6.3.4 In its Chapter 3 on development control, PPS 6 states in its paragraph 3.4 that Local Planning Authorities should require applicants to demonstrate " that locations are accessible". This is described in more detail in its paragraph 3.24 through to 3.27.

6.3.5 As has been shown in all of the various transport assessments undertaken and reported on in the 2001 Environmental Statement, the Scheme's location is of the highest ranking being adjacent to two main public transport modes namely the bus station and railway station. Access by pedestrians, cyclists and disabled is also well catered for confirming the Scheme's compliance with these tests.

6.3.6 In conclusion, I consider that the Scheme complies with the objectives of PPS 6.

6.4 RPGIO REGIONAL PLANNING GUIDANCE FOR THE SOUTH WEST

6.4.1 The RPG states in its paragraph 1.28 that "Public transport in rural areas is generally inadequate to meet all needs and for many the car will remain essential".

6.4.2 It adds in paragraph 1.31 that "Central government policy is to reduce the need to travel and to promote more sustainable transport choices ... " and that "The roles and use of local public transport, walking and cycling also need to be encouraged". The Scheme actively supports these objectives.

6.4.3 In its Section 8, RPG 10 sets out its transport policies. These include TRAN 1 : Reducing the Need to Travel, which recommends " proposing major development ... on sites where there is a good choice of travel by sustainable transport". The Scheme with its new bus station and location adjacent to both the railway station and bus stops for city wide routes complies fully with TRAN 1.

6.4.4 Policy TRAN 5 refers to managing parking demand and supply and the Scheme with its reduction in parking supply assists this policy.

6.4.5 Policy TRAN 10 seeks to provide alternatives to the private car by encouraging public transport efficiency and bus priority measures. It also promotes passenger information facilities. The Scheme supports bus priority measures in Ambury and Manvers Street and will include passenger information in the bus station.

6.4.6 The Scheme therefore is in compliance with the objectives and policies contained in the RPG 10.

6.5 Bath Local Plan

6.5.1 The Bath Local Plan was adopted in 1997 whilst its replacement known as the Bath & North East Somerset's Local Plan has just been though its public inquiry following the Deposit Draft of January 2002. However this new document has not yet been adopted and therefore I shall very briefly comment on the policies in the adopted 1997 plan.

6.5.2 This Adopted document in its paragraph 7.12 refers to the Southgate redevelopment and in its policy R3 indicates that it will permit the comprehensive redevelopment of the Southgate area subject to several objectives which includes "ii) the redevelopment shall make full provision for a functionally efficient public transport interchange and an improved environment for users of public transport services" and also "vi. No substantial increase in parking provision".

6.5.3 The proposed bus station with its high quality glass enclosed waiting area and real time travel information confirms its compliance with that objective whilst the parking provision is again in line with the objectives.

6.5.4 The Local Plan in its policy T12 "requires provision for all developments of onsite servicing". As I have already described the proposed development will have a major underground basement area ensuring no conflict with shoppers whilst the secondary service area off Kingston Road is also an area where it will not conflict with pedestrian movements or other highway users.

6.6 BATH AND NORTH EAST SOMERSET LOCAL PLAN - DEPOSIT

DRAFT

6.6.1 Although this document has not yet been adopted, it has just completed its public inquiry stage and has some weight accordingly I shall comment briefly on the Scheme's compliance with its proposed policies. The Scheme by limiting parking provision and providing a new high quality bus station and improved bus stops conforms with policy T.1 (5) of seeking to reduce growth of traffic by measures which encourage movement by public transport, bicycle and on foot.

6.6.2 Policy T.3 relates to provision of safe convenient and pleasant facilities for pedestrians.  The replacement of teh main highway gyratory around the bus station by a series of pedestrianised shopping streets shows the Scheme complies with this policy.  Policies T.5 and T.6 relate to provision of cycle facilities and cycle parking and the Scheme supports and provides such facilities.  The S106 Agreement includes for a cycle rack contribution of £10,000 to enable the Council to provide additional cycle racks throughout the Scheme as considered necessary by the Council.  This complies with policy T.5 and also T.6.

6.6.3 The Section 106 Agreement also allows for a contribution of £20,000 as a contribution towards provision of a "priority access point" in Manvers Street which is designed to enable bus priority measure to be incprporated.  The Scheme complies with the objectives of policy T.8 regarding traffic management proposals which improve the efficiency and reliability of bus and coach operations.

6.6.4 The draft policy T.12 states that the Council will seek to secure an efficient public transport interchange at Bath Spa Railway/Bus Station.  The Southgate development will be providing this new high quality bus station immediately adjacent to The railway station as well as undertaking improvement to the railway station itself.  The Council will therefore achieve its policy T.12 by our development proceeding.

6.7 Local Transport Plan (LTP)

6.7.1 The LTP (paragraph 3.51) refers to two major public transport interchanges as being the railway station and bus station which are located in close proximity in the City Centre.  It states that approximately 10,000 passengers broad or alight from trains at Bath Spa whilst approximately 17,000 passengers use the Bath Bus Station.  Audit of the interchanges has been carried out by the Council and the LTP highlighted some of the shortcomings in terms of passenger facilities and services.

6.7.2 It refers in paragraph 3.53 to the proposed bus station forming part of the Southgate redevelopment scheme. It indicates also in paragraph 4.87 that should the Southgate redevelopment not proceed and therefore the new bus station not be provided then the Council had a financial contingency allocation to allow them to introduce measures to improve the existing interchange. The proposed redevelopment will therefore provide a much needed transport benefit using private funds.

6.7.3 The LTP in its paragraph 3.80 highlights a number of opportunities which could be exploited including improving pedestrian priority in the City Centre; better bus facilities; bus lanes and an interchange linking the bus station and rail station and safer cycling arrangements.

6.7.4 The Southgate Development will deliver all of these opportunities especially the public transport interchange facilities.

6.7.5 This opportunity is highlighted more forcefully in the LTP paragraph 4.59 where is seeks to encourage development of a new bus/rail interchange in the City Centre and investment in new information systems". All of this will come about as part of the Southgate Development.

7 Objections

7.1.1 In this chapter I shall deal with the individual statutory and non-statutory objections that still remain at the time of the Evidence being submitted to the Inquiry. I will show how either their concerns have been adequately dealt with or are not sufficient to outweigh the benefits arising from the Scheme.

7.1.2 Very few of the objections refer to transport issues but it is these that I comment on.

7.2 Network Rail

7.2.1 Network Rail have objected to a significant number of plot numbers of property forming part of the railway station with the grounds of their objection being that the land to be acquired is operational and required for Network Rail's statutory undertakings. This transport related objection is mainly to do with the property rather than transport issues and is therefore being commented on by other witnesses.

7.3 First Great Western Limited

7.3.1 First Great Western Limited are objecting to the same plot numbers as Network Rail regarding their interest in the railway station but have put forward no grounds of objections.

7.4 Avon Valley Cyclery (AVC)

7.4.1 AVC have objected regarding the property they rent at the rear of The railway station. They list seven grounds for objections of which three relate to transport issues namely:

• "Customers vehicular access will be hindered which will disrupt the business".
• "Limited goods delivery to the store"
• "Loss of passing traffic leads to a security risk"

7.4.2 In response to the first objection stated above, access by the shops customers will not be hindered as the car park to the rear of the station remains as will access to the front of the shop. The removal of the Brunel ramp and the creation of a public square necessitates the access arrangements being modified such that cars to the eastern car park will both enter and leave through the same arch to the east of the station.

7.4.3 Currently this arch is used for exit only but also contains a line of parked cars and therefore by simply removing the cars that are parked within the arch it will be possible to operate two-way running.

7.4.4 With regard to the second objection the two-way arch is capable of accommodating "hi-top" transit vans which I would expect to be adequate for a cycle shop. This is only slightly smaller than the size of vehicle that could operate through the middle of the arch when operating as a one way system.

7.4.5 With regard to the third objection above of a security risk, there is no change to the rear car park and neither to the pedestrian route from south of the river across the footbridge and through the eastern arches. Therefore I see no change or worsening in the security surrounding the shop due to any reduction of passing traffic.

7.4.6 In summary I do not consider their concerns to be well founded.

7.5 First Group Plc

7.5.1 First Group are the main operators of buses in Bath and surrounding area and arethe operator of the existing bus station. One of their objections relates to "thedesign of the replacement bus station including Health & Safety and other operational matters".

7.5.2 As I have already mentioned the design of the proposed bus station has been designed after considerable consultation with First Bus and their subsidiary Badger Line and was accepted by them at the time of the application being granted consent by the Council.

7.5.3 I have however met with representatives of First Bus to discuss the matter and in particular the operation or restrictions on the use of the four metre wide "roadway" through the bus station and the ability of First Bus to permit their buses to reverse off the stands and across this roadway. The second main issue relates to potential use of longer buses of up to 13.5 metre length in the future by First Bus and also by National Express on their coach bays.

7.5.4 The "roadway" through the bus station is a requirement of the Council and the S106 Agreement in order that buses from the south wishing to access the four on-street stops on Dorchester Street immediately adjacent to the bus station can use the bus station "Roadway" to turn round and line up on these on-street stops. This routeing replaces the current highway gyratory which encircles the existing bus station and which will be lost with the proposed development.

7.5.5 First Bus's comments relate to the likelihood of longer buses in the future and their difficulty in avoiding reversing buses manoeuvrlng into this roadway.  Whilst there are benefits from a reversing bus not encroaching on this roadway, this was not an absolute requirement.

7.5.6 Therefore this comment of First Bus can be overcome as the S106 agreement requirement is simply the provision of this roadway and does not exclude its use by manoeuvring vehicles whether reversing off one of the 16 bus stands or in accessing the layover bays to the rear of the station.

7.5.7 However the first two bays which are to be used by the National Express coaches are too close to the entrance to provide adequate inter-visibility between an arriving bus driver and one reversing off Bay 1 and 2 if that bus reverses into the roadway.  The consented layout designed for 12 metre coaches incorporated a "notch" in the bus station building in to which the National Express coaches could reverse from Bays 1 and 2. This avoided the above conflict with arriving buses.

7.5.8 However, First Bus now require a layout capable of accommodating the 12.8 m long coaches already in use by National Express and also the legal maximum length coach of 13.5m with single rear axle. Accordingly modifications are being made to Bay 1 and 2 and the "notch" to improve the manoeuvrability facilities for the National Express coaches (see Figure DHY 4). As a result, the newly acquired 12.8 metre long coaches and any future lengthening to 13.5 metre coaches can be accommodated in Bays 1 and 2 without the reversing manoeuvre encroaching on the arrival roadway.

7.5.9 This revised layout as shown in Figure DHY 4 layout has been submitted to First Bus who have deemed it acceptable. As a result I believe I have amended the design involving only minimal and superficial changes to that that has planning consent such that First Bus' points on operational matters are now satisfactorily resolved.

7.5.10 First Bus indicated that to improve safety within the bus station they wish to operate a traffic light within their curtilage which will bring all entering buses temporarily to a halt before being allowed to proceed through a flashing amber light. This is effectively a means of bringing bus speeds down such that line of sight operation is deemed to be adequate.

7.5.11 We understand that the installation of such a red/flashing amber signal would be acceptable to the Highway Authority subject to it being located sufficiently off the public highway to allow the incoming bus to halt without obstructing either the public highway or the pedestrian route from the Southgate footbridge.

7.6 Somerfield Stores Plc

7.6.1 Somerfield have objected regarding their property at 4 Marchants Passage and included four grounds of objection including one that states "no certainty of sufficient car park provision.

7.6.2 As I have already mentioned my company undertook considerable amount of investigation and analysis of both existing and both future parking requirements in Bath City Centre and were able to satisfy the Council that we had an appropriate provision commensurate with a sustainable development. In addition the Council were satisfied that the reduced parking during construction could be handled by the remaining City Centre car parks in conjunction with increased bus usage and Park and Ride.

7.7 ROSEBY LIMITED

7.7.1 Rosebys who operate from 5 Railway Street have listed five grounds of objections of which one states "no information has been provided as to how the Wilkinson Eyre station scheme overcomes the problems of the previous scheme".

7.7.2 I have already described the improvements of the new bus station over that existing  specially with regards to passenger waiting areas, travel information and also accessibility on foot from the city centre, city bus stop and the main line railway station. I therefore consider that the scheme as drawn and consented does overcome the problems of the previous bus station.

7.7.3 They also stated in a further objection that "the objector can demonstrate alternative layouts to enable their interests to be excluded from the Order". Having been involved since 1996 in all of the conceptual work to formulate the various schemes that have been prepared and submitted for planning approval. I remain sceptical that the object has managed to identify such a layout. I am still awaiting sight of these alternative layouts so I cannot comment further at this stage.