ANNEX 6. Comments on Transport Assessment. Public transport

Transcription

1 ANNEX 6 Comments on Transport Assessment Public transport The two important bus services running to Haverfordwest (411) and Fishguard (413) include deviations for schoolchildren, and do not run on Sundays and public holidays. The 403 connects coastal and peninsular places with St David s. The other services (400 and 404) operate in the summer months only (i.e. May to September inclusive) and are intended mainly for visitors. The map of bus stops (Fig 6) omits a stop at the south end of New Street, in St David s, and has no scale, which gives a misleading view of distances to bus stops. Comparing Fig 6 with Fig 2 (which shows the area within 1km of the proposed development) it is clear that all existing bus stops in St David s are more than 200m from the entrances to the proposed development, contrary to the caption to Table 1, and some buses will only stop at least 500m away. The Assessment does not consider the importance to local residents of local taxi services, which are a vital complement to bus services; nor does it consider carsharing and similar schemes, one of which is under development at Oriel-y-Parc, the National Park visitor centre in St David s. The roads to St David s Approach roads to St David s are not good enough to take much traffic: at Solva the road connecting Upper and Lower Solva is narrow and steep, and goes over a narrow bridge, resulting in congestion at busy times, and at Newgale the road is steep and liable to be closed by winter storms, and a by-pass is under consideration. Parking for disabled people In respect of disabled people accessing the site, we assume that they will have to access vehicles in the road area of the development as parking spaces will not be wide enough to mobilise a wheelchair alongside a vehicle, if there are vehicles parked in adjacent parking bays. As 38 of the dwellings are affordable, with 2 dwellings identified as accessible bungalows, there is an assumption that the bungalows and some of the ground floor flats at least will be occupied at some time 1

2 in their lifetime by people with mobility needs, either being wheelchair dependent or reliant on a mobility trolley or buggy. Given the projected age span of the UK population and that people are living significantly longer, but not always in the best of health, the need for accessibility to properties by wheelchairs and mobility trolleys is likely to increase with time either from a resident of the dwellings, or from somebody simply wishing to visit them. It is not reasonable to make no parking provision available for such users, and does in fact appear to be contrary to the provisions of the Equalities Act 2010, which requires access to facilities and the buying or renting of property or land to be supplied in ways so as not to discriminate against people with disabilities. It is also contrary to the requirements of PPW in regard to designing new developments to be inclusive developments. As well as the requirements for disabled parking, there is an expectation that a number of the affordable dwellings will be occupied by families with young children, or that they will be visitors to the site. Good practice would therefore have been to provide layouts and parking provision that is also suitable for buggy users and getting child car seats in and out of cars. TRICS estimates of additional traffic There is no sign that the TRICS results have been rank-ordered, scatter-plotted or cross-tested to see if they are skewed by any of the survey sites, as the TRICS Good Practice Guide recommends. The published output of the TRICS on-line analysis, but not the text of the Assessment, shows the date of analysis (May 2017) and the latest date of the survey data (January 2017). Residential traffic Looking at the 43 housing survey sites and survey days selected (in Appendix C) it is immediately noticeable that all are in TRICS land use category 03-A privately owned housing. The Assessment candidly admits that this category does not, in fact, reflect the varied and mixed character of the housing that is actually proposed, which includes affordable housing and flats for rent as well as detached and semidetached private houses. (The TRICS database includes more closely comparable housing types, such as 03-A-M mixed private and affordable flats and houses.) The reason given for this discrepancy is that the category used will produce an overestimate rather than an underestimate of the traffic likely to be generated by the actual 2

3 households, and the estimate will therefore be robust. This is lazy reasoning, and does not inspire confidence that the survey sites have been chosen, or their data have been analysed, with care. For instance, the proposed housing will be within walking distance of various shops, a primary school, pubs and restaurants, doctor s and dentist s surgeries, and several kinds of public amenity as well as places to walk dogs, so daily foot traffic may be expected to be relatively high. The estimates produced by the Assessment s use of TRICS data and software does not appear to reflect this, however, which raises serious doubt as to whether appropriate survey sites have been selected. The survey days selected are only weekdays (4.14; Appendix C, page 2); this is probably acceptable for domestic households, which may perhaps be expected to generate more traffic on weekdays than on weekends, but the filter should have been explained. No explanation is provided about the use of public transport as a possible filter. Hotel traffic The information that is given about the hotel survey sites, especially their location categories and sub-categories, suggests a variety of sites, not necessarily all of them very like Glasfryn Road, St David s. This information, together with the list of local authority areas where they are and other facts (the latest data being from September 2014, and the location categories and sub-categories) is enough to deduce the identity of most of them. The locations are set out in the table in this Annex (or Appendix). Table of TRICS hotel survey sites Although the Assessment does not identify the TRICS survey sites used, the TRICS results in the Assessment should be accessible to a TRICS Audit, which would identity these survey sites. (An Audit may be performed by a subscriber to the TRICS consortium s software.) Provisionally, however, we can deduce the identity of some or all of the survey sites used. This is feasible because of the small number of sites used, which the Assessment lists by abbreviated local authority area (Appendix D, page 1), and the more limited choice of sites in the TRICS database (427 hotel sites as of January 2018, generally only two or three in any one area), in conjunction with other information given in the Assessment (4.19), such as the particular categories and subcategories of the sites, the fact that they were all surveyed manually, and 3

4 the latest date of the surveys being The probable survey sites used are set out in the table below. Table: Probable TRICS survey sites used for Glasfryn Road Transport Assessment Local authority area AG BU Probable site (with TRICS id number) 1111, Boutique B & B, Arbroath 1121, Holiday Inn, Aylesbury CA 1124, Travelodge, Cambridge CF (2) 1127, MacDonald Hotel, Cardiff 1128, Holiday Inn Express, Cardiff DS 1148, Days Inn, Derby DV (2) GS HI NF NT 1153, Premier Inn, Plymouth 1154, Future Inn, Plymouth 1175, Premier Inn, Cheltenham 1189, Express by Holiday Inn, Inverness 1207, Holiday Inn, Norwich 1212, Premier Inn, Nottingham Bed rooms Location 4 Edge town/ residential 139 Edge town/ out of town 120 Suburb/builtup 100 Edge town centre/ industrial 87 Edge town centre/ residential Survey date Comments 22/5/12 Only AG hotel in database 1/10/14 Includes conference, function, sports facilities (later resurvey 2014) 16/10/09 In urban regeneration area, between city centre and A11/M11 17/10/06 Includes bar restaurant 16/7/12 Function rooms; part of Cardiff Bay development 100 Suburb 23/6/04 Includes 120-seat restaurant, next to county cricket ground 107 Edge town centre 110 Edge town/ industrial 67 Suburb/ residential 94 Edge town/ commercial 21/10/09 Restaurant open to public, staff shared with another PI 50m away (not in database) 18/7/12 In business park; includes restaurant, conference rooms; off A386 28/11/2013 2km from town centre; restaurant, amenities nearby 25/5/06 Includes conference centre; next to pub restaurant; off A9, A Edge town 30/9/10 Includes restaurant 87 Edge town centre/ builtup 24/6/13 Includes barrestaurant; near railway and bus stations 4

5 Local authority area Probable site (with TRICS id number) NW 1213, Travelodge, Newport (Mon) TV (2) WL WS WY 1224, Premier Inn, Middlesbrough 1226, Thistle, Middlesbrough 1234, Thistle, Swindon 1249, Express Holiday Inn, Crawley 1251, Express Holiday Inn, Bradford Bed rooms Location 62 Town centre/ high street Survey date Comments 14/10/10 Poor public transport? Former cinema (only NW hotel in database) 74 Suburb 18/12/09 Restaurant nearby 132 Town centre/ commercial 3/10/13 Includes restaurant, sports, conference facilities 95 Town centre 9/7/04 Includes conference rooms, bars; railway and bus stations nearby (1235, only other WL hotel, is similar) 74 Suburb 7/12/09 Includes function rooms; pubrestaurant nearby 120 Edge town centre 17/5/05 Large restaurant; in leisure park; railway station nearby (alternatively, 1252, a smaller hotel) The compatibility of the survey sites chosen with St David s, assuming that they have been correctly identified, is not explained. The location categories (column 4 in the table) amplify what is stated in the Assessment (Appendix D, page 2), and some sites immediately raise doubts that they are realistically comparable with Glasfryn Road and St Davids. The date of each survey (column 5 in the table) is useful, as it indicates the likely relevance of the data to the possible seasonality of use of the proposed hotel in St David s. Only six of these particular surveys were carried out in the summer months. The comments (column 6 in the table, above) give some of the characteristics of each site, which are stated in the TRICS database precisely in order to help choose suitably comparable sites. The hotel in St David s is proposed to have only a small restaurant in addition to bedrooms, and not have any other facilities such as conference, sports or function rooms, which also raises doubts as to the suitability of many of the sites identified. 5

6 References LDP (Local Development Plan, ), Pembrokeshire Coast National Park Authority (PCNPA) MFS (Manual for Streets), Welsh Assembly Government 2007 ( government/ uploads/system/uploads/attachment_data/file/341513/pdfmanforstreets.pdf, accessed February 2018) RTP (Regional Transport Plan), South-west Wales Integrated Transport Consortium of local authorities ( accessed February 2018) SPG (Supplementary Planning Guidance: Parking standards), PCNPA 2011 TAN18 (Technical Advice Note 18: Transport), Welsh Assembly Government 2007 ( gov.wales/ docs/ desh/ publications/. accessed February 2018) TRICS database, TRICS Consortium 2018 ( accessed February 2018) TRICS Good Practice Guide, TRICS Consortium 2016 ( accessed February 2018) 6