Response to Planning Application for Brighton Station site Download as Word document


Background

This submission forms the response of three groups representing the interests of cyclists in the Brighton & Hove area. It sets out the views of:

  • Sustrans is a national charity working on practical projects to encourage greater use of sustainable modes of transport. Its primary project is the National Cycle Network Sustrans also developed the concept of Safe Routes to Schools, which has now been adopted as a policy goal by the Government and local authorities, and it is now working with the DTLR and Railtrack to develop Safe Routes to Stations.
  • CTC is the largest national groups representing cyclists in the UK, with over 50,000 members. It campaigns for improved conditions for cyclists, as well as working to encourage cycling through projects such as National Bike Week. At a local level it operates through the Cyclists’ Rights Network, whose local members have endorsed this submission.
  • Bricycles, the Brighton, Hove and District Cycle Campaign, has represented local cyclists for over 20 years. It produces a regular magazine with information about local cycling issues. Along with the other groups it works closely with Brighton & Hove Council.

There is strong Policy support for measures to improve conditions for cycling, at national, regional and local level. These range from PPG13 to the Brighton & Hove Local Transport Plan. Central Government has set a target of a trebling of cycling by 2010 (from 1990 levels). In order to achieve this target it is not sufficient to ensure merely that developments do not disbenefit existing cyclists — they must include positive measures aimed at encouraging modal shift from other, less sustainable modes.

We are concerned that the development will not meet this goal. It does not meet the standards set for it in the planning brief, or indeed in the early publicity produced by the development consortium. These implied that sustainable transport, particularly walking and cycling, would be placed at the heart of the development. We see no evidence from the application that this is the case. Although there are some good measures proposed, we believe that the development as it stands will not contribute to an increase in cycling. We are therefore calling on the council to ensure that improved measures to encourage cycling are included in the development. If this cannot be achieved then we cannot support the application.

Note that Route 20 of the National Cycle Network will run north-south along the A23 corridor. In order to maximise the levels of cycling associated with the development we suggest that it be routed via the proposed cycle route along New England Road. This will gives links to the existing routes north-west of Preston Circus and to the North Laine area south of the development. Having the NCN pass through the site will also help to raise the profile of cycling.

General matters

This response is concerned primarily with transport issues, particularly how the proposed development will affect cycling. However, we do have a number of more general concerns regarding other aspects of the development.

We are concerned about the impact of the proposed superstore on the London Road shopping area. This is currently well-suited to visits by public transport users as well as pedestrians and cyclists. Any loss of retail in London Road caused by the development will therefore be detrimental to the sustainability of the area. We would therefore like to see further measures to ensure the continuing viability of London Road.

A further concern is the impact of the development on the built environment. In particular the impression is given by both the artist’s impression and the model that the streets and paths in the development will feel dominated by high buildings on both sides. We are keen that this form of "canyon" effect is avoided as it does not lead to a people-friendly environment. Although we support high density accommodation in urban areas, this must be accompanied by open streetscapes.

Detailed comments on cycling issues

Our comments on the details of the application as they affect cycling can be divided in four main areas: east-west routes through the site (including links to the station); north-south routes (excluding the propose Greenway); the Greenway; and measures off site. These are discussed below. Annotated plans are enclosed giving further details.

In addition we note that no details are given regarding cycling parking, both for the proposed superstore and other retails units, and in the residential units. It is crucial that high-quality cycle parking is provided for both residents and visitors to the site.

East-west routes

These can be further split into the key route between London Road and the station (along the Ann Street axis), and other routes.

We would like to see the following issues addressed on the route along the Ann Street axis. The detailed design of this route is crucial if cycling to have significant modal share of journeys to and through the site. Note that any requirement for cyclists to dismount (apart from at the proposed lift to the station) is unacceptable and will serve to reinforce the feeling that cycling is not be considered seriously.

  1. At London Road it is of the utmost importance that a link is provided between Ann Street and Baker Street. We welcome the proposed crossing shown on the plans. Improvements that might be made include ramping the cycle track in Ann Street up to footway level, to slow the speed of cyclists. Lead-in lanes must be provided at the Advanced Stop Lines (ASLs) in London Road and Baker Street.
  2. To improve Ann Street we suggest that the disabled parking is removed from the section east of Providence Place, and relocated in London Road itself. Not only with this benefit disabled drives by placing the spaces closer to the shopping area, it will also remove the need for reversing out of the spaces and up a narrow hill. This area could then be resurfaced to give a more attractive area with pedestrian priority (as was shown on early leaflets for the development!).
  3. A 20mph limit should be applied to the whole of Ann Street, as well as Road 2 and St. Peters Street. This will benefit children at St. Bartholemews School as well as cyclists and pedestrians.
  4. The square outside the superstore must be redesigned to give a ramp and gradient which allow cycling. As noted above we cannot support dismounting in this area. This is the key link to the station and therefore cyclists must be able to cycle throughout the journey.
  5. However an alternative acceptable route may be possible using the proposed cycle track north of Ann Street. This will require a ramp to be provide instead of steps over the entrance to the underground car park. This route has other benefits as it then allows a link to the station avoiding the lift. In this case alterations will be needed at the junction of Road 1 and Road 6 so that cyclists can cross Road 1 safely. A mini-roundabout would help to achieve this. It would also slow traffic on Road 1 and minimise queuing into/out of the station at peak times.
  6. Other east-west routes are those along New England Road, York Hill and Cheapside, Along New England Road ASLs with lead-in lanes are needed for eastbound journeys. York Hill should be made two-way for cyclists. This was agreed in discussions with the council but has made been shown on the plan.
  7. At Cheapside there should be a cycle lane south of the junction with Road 2. This should feed into the ASL, and lead-in lanes are also needed at the other ASLs at this junction. A continuation of the westbound cycle lane should be provide at least to Blackman Street, and preferably as far as the cycle track leading to the lift.
  8. The lift to the station must run on a 24-hour basis and be large enough to carry at least two bicycles, or one bicycle and a wheelchair.
  9. At the new entrance to the station, details are needed of the precise arrangement for cyclists. Cycling should be allowed between the lift and the station concourse. Similarly the link between the Greenway and the station needs to be designed in detail. It should not simply stop, as shown on the existing plans.

North-south routes

There are two main east-west routes through the site: along New England Street/Road 1, and along Elder Place/Providence Place. While the Elder Place route will be along roads with less traffic, it will also be less direct for the majority of journeys and does not serve the key destinations on the site. Attention should therefore be concentrated on New England Street. This is particularly important for journeys from the north (Preston Park area) to the station, where use of Elder Place involves a short descent which will then require a climb at the ramps north of the superstore.

  1. The combination of New England Street and the Greenway offers a more direct and convenient route to the station than the route via Elder Place. Cycle lanes are therefore required in both directions along the length of New England Street as far south as Road 6. A southbound cycle lane is also required along Road 6 south of the junction with the Greenway, (this is discussed separately below).
  2. At the junction between Road 1, New England Street and Road 4 a lead-in lane is needed at the ASL in Road 1. A southbound cycle track avoiding the traffic signals should be provided into Road 4.
  3. At the exit from London Road car park cars should give way to cyclists and pedestrians crossing on the speed table. This will help to encourage cycle trips to the superstore.
  4. The detailed design of the area east of the superstore is crucial, and this should use high quality materials with the cycle track at a slightly lower level and demarcated using 45° half-height kerbs.
  5. At the speed table at junction of Ann Street and Road 1 the carriageway should be narrowed to an absolute minimum to prevent taxis and other vehicles parking on the corner and hence blocking the cycle route. In addition bollards or some other features will be needed to prevent vehicles from driving along the cycle track.
  6. Road 1 itself should be made more residential in character by reducing its width to 5.5m. This will enable the footways to be widened and help to reduce traffic speeds (as noted above Road 2 should have a 20mph speed limit). The southbound contraflow cycle lane could also then be shortened slightly.
  7. We strongly support the proposed closure of Elder Place at New England Road, which will require bollards or some other physical measure. Care must be taken in the design to ensure that this is not then blocked by parked vehicles. The section to the south of the closure must then become two-way for all traffic.
  8. The remainder of Elder Place is currently a fairly daunting area for cycling, with no road markings. We would like to see this length of road formalised, with a centre line marking. This is of particular importance given the anticipated increased use of London Road car park. At the same time the eastern footway should be increased in width as this is almost continually blocked by cars parked at 90° to the kerb.
  9. The narrower section of Providence Place north of Ann Street should be made one-way southbound, with a contraflow lane for cyclists. This will prevent rat-running. Rear deliveries to shops in London Road will continue to be accessed via Elder Place.
  10. We suggest that further attention is paid to the area south of Ann Street, where stopping up of the northern section of St. Peters Street has not been a success. A Home Zone could be created in this area, with Providence Place be realigned slightly to take delivery vehicles from the section north of Ann Street.
  11. Finally we would like to see confirmation that cycling will be permitted on the north-south path through the centre of the residential part of the development. This is crucial in order to allow access to the new dwellings. A speed table should be provided at the junction with Road 1.

Greenway

Over the past 20 years Sustrans has created many paths along former railway lines, and indeed is recognised as a national and international authority on the creation of Greenways. We are therefore very concerned to see the approach taken by the proposed Greenway on the Brighton Station site. Very little attention appears to have been paid to its function, and how journeys can be attracted both by foot and bicycle.

It is Sustrans’ experience that without a constant throughput of users, Greenways rapidly deteriorate. This can lead to a possible increase in crime and anti-social behaviour. Sustrans has worked closely with the Association of Chief Police Officers and they support this general view (see attached leaflet). In particular we have major concerns about the section north of Road 6. As the plans currently stand this is effectively a dead end. The proposed ramp to New England Road is very steep and narrow, and will deter virtually all users.

  1. The section between Road 6 and the station should be designed as a high quality route for access to the station, with a maximum gradient of 1:20. The path must be surfaced in tarmac and should be a minimum of 3.5m, segregated between cyclists and pedestrians. Good lighting must be provided, and planting must be sited to avoid obscuring sight-lines.
  2. At the speed table crossing of Road 6, measures should be taken to slow motor traffic and ensure that Greenway users can cross safely and conveniently.
  3. North of Road 6 the Greenway should be designed as an unsegregated shared use path, at least 3m wide and surfaced in tarmac or ‘Fibre-dec’. Again, good lighting is needed. Use of the path by pedestrians and cyclists will not conflict with the possible use as a local nature reserve, and will in fact make it easier to access the area.
  4. A design should be drawn up for a ramp between Boston Street and the Greenway. Ramps have been built in much more complex situations than this and we feel that with care and attention to detail one is possible here. However it is accepted that any ramp will have a gradient greater than 1:20 and may involve a ‘switchback’ arrangement.
  5. The ramp to the south side of New England Road needs to be considered in more detail. As the plans currently stand it will deter the majority of potential users, being steep and narrow. Every effort must be made to improve this link.
  6. Similarly, negotiations should be opened with Railtrack to allow use of the redundant bridge span over New England Road. This is an extremely important link and one that must be retained. The council should investigate taking over the bridge in return for a payment from Railtrack and the developers sufficient to ensure future maintenance. Note that Sustrans may be able to carry out an assessment of the bridge as we have extensive experience of such structures.
  7. If this bridge is available, then it opens up the possibility of a much more attractive ramp to the north side of New England Road via the open space between the disused and active railways. Indeed this ramp was shown on early plans submitted by the developers, as well as on the model placed on public display.

Off-site matters

In order to improve access by bicycle to the site, measures will also be needed in the surrounding areas. Some of these have been discussed above, such as improvements at the junction of Baker Street and London Road. Other improvements are needed at Preston Circus and St. Peter’s Place, where the existing cycle facilities require some minor changes to improve safety and convenience for cyclists.

Cycle parking

This is a crucial issue if cycling is to be encouraged as a significant mode of transport to and through the site. There are two main areas where parking is required: to serve the superstore and other retail/business uses, and in the residential units.

At the superstore cycles racks should be provided immediately adjacent to the main entrance, preferably under cover. A sufficient number should be provided to allow for increased demand. Other racks should be provided at regular intervals throughout the site, particularly outside key destinations.

In the residential areas lockable cycle stores should be provided for each dwelling. These should be sited close to the entrances so that cyclists do not have to walk long distances (i.e. there should not be one central store). Visitor parking racks must also be provided.

Other transport issues

We have a number of concerns regarding other transport issues associated with the development. The residential element of the development seems ideally suited to the establishment of a car club, and we would urge the council to include a requirement for this in any planing conditions. If a club is to succeed it will need dedicated parking spaces in the residential development itself.

Although it is only part of the outline application, we are concerned about the Home Zone proposed in the section of the site to be used by the Language School. This does not appear to have been given any serious thought, and more details will be required. We would be keen to see Home Zones covering other areas in the site, such as Ann Street.

We understand that no bus routes have been proposed to serve the development. This is of great concern as it will contribute to an overall increase in the modal share of car journeys. We cannot reconcile this with the vision set out in early leaflets for the development of placing sustainable travel at the heart of the development.

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