Wednesday 12 February 2014

Oppose planning application for new Merlin Entertainments attraction at County Hall

Merlin Entertainments have a planning application for a new commercially-sensitive-so-undisclosed attraction to open at County Hall (already home to Merlin Entertainments existing London Eye and Aquarium, oh and the recently moved London Dungeon) which they expect to attract 600-700,000 visitor a year, whereas the Movieum it will replace attracts c50,000.

The proposed new visitor attraction is predicted to generate an additional 3-4% of the existing visitor numbers.

To the best of my knowledge no meaningful measures have been taken to make cycling better at County Hall (particularly the cycle route on Belvedere Road) with any of the previous developments. However, to the detriment of people on bikes, the large number of pedestrians on the river front has led to County Hall inhibiting cycling along the Thames Path.

I urge you to spend five minutes on Lambeth's website opposing the plans until a substantial improvement in the cycle route behind County Hall and cycle parking on site is undertaken. Please do it now if you can - there's only until February 18th. (I'll stick some photos in the blog when I have time, but don't delay acting until I do!)

The application is number 13/06055/FUL on and once you have signed in to the site you can comment. Feel free to cut and paste bits from my objection (publicly viewable) or from this blog, or if you're a planning expert, make comments on my blog for people to include in their objection. Below I detail the policy areas that I consider are not being engaged with in this application.

The Transport Assessment, written by Atkins, for the new attraction confirms that the privately owned part of Belvedere Road behind County Hall is a cycle route - National Cycle Network route 4 as it happens. It is also a London Cycle Network route and a planned part of the Mayor's new central London cycle grid.

The owners of County Hall choose to make it a difficult area to enter and exit, and recently tried to make it even worse than it is.

They also provide no public cycle parking in their grounds. There is none on their section of Belvedere Road and none on Forum Magnum Square.

The Transport Assessment states (my emphasis):
4.15. Cycle parking stands are provided to the south of the concourse area of the London Eye located adjacent to Belvedere Road as well as numerous other locations around County Hall. In addition, cycle parking is also provided at Waterloo Tube Station a seven minute walk from the new visitor attraction and also adjacent to Royal Festival Hall on Belvedere Road a five minute walk from the site. 
8.10. No additional cycle parking is proposed as part of this planning application.

The absence of cycle parking within the grounds of County Hall is glossed over and nothing is said at all about the dreadful quality of the cycle route access / egress at County Hall, nor are any measures proposed to improve it.

So, let's see how this stacks up to policy that's cited within the Transport Assessment. Let's start with the big one, National Planning Policy Framework: Transport:

2.1. National Planning Policy Framework (NPPF), published March 2012 sets out the Government’s planning policies for England and how these are expected to be applied. There are 12 core principles that underpin planning and decision-taking and the key one for transport is the promoting of sustainable transport, namely:
actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and
 focus significant development in locations which are or can be made sustainable.
In my view, no improvements to a poor quality cycle route coupled with no more cycle parking seems to fly in the face of that.

2.2. A key planning objective is to ensure that jobs, shopping, leisure facilities and services are accessible by public transport, walking and cycling. When preparing development plans or considering planning applications, local authorities should:
 accommodate the efficient delivery of goods and supplies;
 give priority to pedestrian and cycle movements, and have access to high
 quality public transport facilities;
create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians, avoiding street clutter and where appropriate establishing home zones;
 incorporate facilities for charging plug-in and other ultra-low emission vehicles; and
 consider the needs of people with disabilities by all modes of transport.

I would suggest that the transition from the road to the cycle path here exemplifies pedestrian / cyclist conflict and street clutter.

Now, what about regional level? The Mayor's Transport Strategy 2010 includes:
2.5. The Mayor’s transport vision is: ‘London’s transport system should excel among those of world cities, providing access to opportunities for all its people and enterprises, achieving the highest environmental standards and leading the world in its approach to tackling urban transport challenges of the 21st century.’
2.8. In October 2013 Revised Early Minor Alterations were published. A revision which is applicable here
New developments should provide cycle parking and cycle changing facilities to encourage more cycling. Cycle parking provided for staff should be suitable for long stay parking. 
Quite clearly the cycle route access and egress at County Hall falls far short of world leading infrastructure, as does an absence of public cycle parking on the site.

At borough level, the Lambeth Local Development Framework Core Strategy 2011, section 4 includes
(g) Promoting walking and cycling, including through improvements to existing provision and
provision in and around new development for cycling, cycle parking, the public realm and
transport and highway infrastructure. 
Move along, no improvement planned here

At local level there's the Waterloo Area Supplementary Planning Document (SPD) which states,
New developments should connect to and improve the cycle network with direct, safe and
well-lit cycle routes.
and, finally, let's not forget Lambeth's Transport Plan 2011
2.13. Lambeth’s Transport Plan objectives are:
 Promote sustainable healthy travel behaviour
 Improve the condition of principal roads
 Improve Air Quality
 Reduce the perceived and actual danger on Lambeth’s roads
 Reduce CO2 emissions 
The Transport Consultancy fails to cite Lambeth's Cycling Strategy 2013, with its target of 20% of trips by cycle by 2020, and the demand for partnership working to achieve this. I would suggest that the application shows a distinct disinterest in helping achieve this.