STATEMENT OF CASE ON BEHALF OF IMPERIAL WAR MUSEUM GROUP

Transcription

1 TRANSPORT AND WORKS ACT 1992 TRANSPORT AND WORKS (APPLICATIONS AND OBJECTIONS PROCEDURE) (ENGLAND AND WALES) RULES 2006 THE TRANSPORT FOR GREATER MANCHESTER (LIGHT RAPID TRANSIT SYSTEM) (TRAFFORD PARK EXTENSION) ORDER STATEMENT OF CASE ON BEHALF OF IMPERIAL WAR MUSEUM GROUP 1 INTRODUCTION 1.1 This Statement of Case is submitted on behalf of Imperial War Museum Group ( IWM ). 1.2 IWM is a family of five museums: IWM London; IWM North in Trafford, Greater Manchester; IWM Duxford near Cambridge; the Churchill War Rooms in Whitehall, London; and the historic ship HMS Belfast, moored in the Pool of London on the River Thames. IWM is unique in its coverage of conflicts, especially those involving Britain and the Commonwealth, from the First World War to the present day. IWM seek to provide for, and to encourage, the study and understanding of the history of modern war and 'wartime experience' and are proud to be regarded as essential sights of London, Cambridgeshire and Greater Manchester. 1.3 IWM has been the recipient of a Notice of Application to acquire land compulsorily which have been served in relation to the Transport for Greater Manchester (Light Rapid Transit system) (Trafford Park Extension) Order ( the Order ) under Rule 15 of the Transport and Works (Applications and Objections Procedure) (England and Wales) Rules THE ORDER 2.1 The Order is promoted by Transport for Greater Manchester ( TfGM ) which is an executive body of the Greater Manchester Combined Authority and, prior to the Greater Manchester Combined Authority Order 2011, was known as Greater 1

2 Manchester Passenger Transport Executive. It would permit TfGM to construct and operate works and compulsorily to acquire land and rights in land for the provision an extension to the Metrolink System through the Trafford Park area of Trafford Borough in Greater Manchester. The proposed new route would join existing tramway routes at the existing Pomona Metrolink stop and terminate at the Trafford Centre retail and leisure complex. 2.2 The powers sought include powers to construct works, including street works, powers for the compulsory acquisition of land and interests in land, powers for the temporary use of land, powers to attach equipment and carry out protective works to buildings, powers to operate the transit system and powers to regulate or prohibit traffic. 2.3 IWM North in Trafford is located on the north of Trafford Wharf Way in the vicinity of the site for the proposed Imperial War Museum Tram Stop and the Order if made will authorise the construction of works in the vicinity of IMW, comprising the end of Work No 1 and Work No 2 in the Order. Figure 1: Route Refinement in Wharfside Area 2.4 From the Imperial War Museum stop, (shown above) it is intended that the alignment of the tramway continues westwards, via a signalised junction, to run segregated in Trafford Wharf Road. Trafford Wharf Road is to be realigned and 2

3 widened to accommodate the tramway, along with the following movement modifications: The junction of Trafford Wharf Road / Elevator Road will be restricted to left-in, left-out movements. Movements from the properties along Elevator Road will remain available in all directions Between Elevator Road and Warren Bruce Road, right turn movements across the tramway are proposed to be prohibited to the properties either side, except by emergency vehicles. Access and egress to all properties along this section will become left-in and leftout. 2.5 As a fronatger to Trafford Wharf Road IWM has an interest in the subsoil beneath the road and has been served a Notice of Application to acquire land compulsorily in respect of plot 1305 and 1306 comprising and square metres and of public highway and footway being part of Trafford Wharf Road). Plot 1305 is required for temporary use and Plot 1306 is land to be acquired or used. 2.6 While TfGM have consulted with IWM North over this development and in principle IWM are supportive of the scheme, the application for the Order and the powers that will be secured for street works and traffic regulation has raised some concerns which either were not considered during the original consultation, or the full impact of which were not realised at that time and which need to be addressed through modifications and the planning conditions to be attached to the to the direction being sought for deemed planning permission for the reasons explained below. 3 IWM NORTH 3.1 IWM North is situated on the banks of the Manchester Ship Canal and opened on 5 July It is the youngest of IWM s five branches and the first outside the south-east of England. Since opening it has welcomed over 3 million visitors, won almost 30 awards and is regarded as an essential sight of Greater Manchester. 3.2 IWM North is the first UK building to be designed by world-renowned architect Daniel Libeskind, who designed the Jewish Museum in Berlin and was recently behind the masterplan for the Ground Zero site in New York. Clad in aluminium, the landmark building is a visionary symbol of the effects of war. Libeskind wanted the building to be a symbol of the effects of war, so he came up with the concept of a globe shattered into three pieces - and though it s been put back together, it will 3

4 never be the same again. That s why IWM North is made up of the EarthShard, WaterShard and the AirShard a piece of the building to represent conflict on land, sea and in the air. Figure 2: IWM North 3.3 IWM North is free to enter, with a charge for car parking and a small fee for visitors to go onto the viewing platform. As such IWM North is heavily reliant on secondary spend for income to support the museum s operation. In order to maintain and increase visitors, and so help to capture secondary spend, the museum has a regular changing programme, including temporary exhibitions (every 9 months on average), and a more frequent special event programme, that often involve bringing large objects/artefacts into the building. Additionally, as one of 5 museums, objects may be transferred out of the museum and to other branches, or for special touring exhibition programmes. 3.4 The period of construction coincides with a number of significant anniversaries that IWM will be leading, including the First World War Centenary and annual commemorations such as VE Day, VJ Day, and Holocaust Memorial Day. We would expect to have events programmed to support these activities, requiring loading access, and expect higher than average visitor figures. IWM also expects significant interest in visiting during the course of

5 3.5 The museum is also very popular with schools, and has a wide-ranging education programme that encourages visits from across the North West. The vast majority visit by coach, and during term time coaches are visiting daily. 3.6 IWM North is also an increasingly popular destination for corporate events, with a 20% increase in turnover last year. These evening events will often involve contractors bringing in equipment (lighting, furniture, rigging etc). These events happen at least weekly and during peak periods November/December in particular - can be daily. 4 SUBMISSIONS AS REGARDS THE POWERS SOUGHT 4.1 IWM s concerns relate to activity associated with the proposals both post construction and during the construction phase. Post Construction Concerns 4.2 Post construction IWM is concerned about the movement modifications associated with the proposals. As explained above the junction of Trafford Wharf Road / Elevator Road will be restricted to left-in, left-out movements and between Elevator Road and Warren Bruce Road, right turn movements across the tramway are proposed to be prohibited to the properties either side, except by emergency vehicles. Access and egress to all properties along this section will become left-in and left-out. 4.3 This proposed compulsory left turn in and out of IWM s three vehicular entrance/exits will cause a major issue with vehicular access & egress for visitor and business traffic to the Museum site. The left turn only proposal will require vehicles to make convoluted and particularly for visitors who are unfamiliar to the area confusing detours to reach the Museum. 4.4 IWM is also concerned about the impact of this proposal during the Football season: On match days at Old Trafford (every other Saturday), with the emptying of the Stadium after the match, the roads around the area are gridlocked. This proposal means that visitors and staff leaving IWM North at this time cannot avoid this gridlock, thus compounding the traffic situation and potentially deterring our visitors from visiting again. 5

6 4.5 Ideally IWM would like the compulsory left turn only proposal to be dropped, but failing this IWM needs guarantees that there will be a clear intuitive route for vehicles to and from the Museum, easy to follow with effective directional signage provided for users unfamiliar to the area and request that such directional signage be secured through TfGM entering into an agreement with IWM committing to provide such signage to IWM s satisfaction and through the planning conditions. This route would also need to be of sufficient width for coaches and other large vehicles to navigate, and that on match days, avoids the vicinity of Old Trafford. 4.6 IWM is also concerned about the proposed size of the entry/exit points and access route widths and turning points outside IWM North. The museums requires regular access for a wide range of commercial and trade vehicles to all three vehicular access points, specifically Coaches & buses (Visitor Car park entrance), HGVs (all three access points) and low-loaders (for large exhibits, Visitor Car park entrance). IWM requires appropriate evidence that there is sufficient space planned for the range of vehicles to turn on to and out of IWM North s premises and that the final design of the entry/exit points and access route widths and turning points outside IWM North secures sufficient space. IWM require TfGM to enter into an agreement with IWM committing to secure sufficient space and the planning conditions requiring details to be submitted should make this a specific requirement. At present the spaces for turning on the plans appears tight. 4.7 TfGM has indicated in correspondence that as a consequence of the proposals there will be the requirement for an operational plan for the use of the middle entrance gate to the ramp serving IWM North for major HGV/low-loader movements. In respect of any operational plan the details need to be understood and approved prior to commencement of the proposals. During the construction phase 4.8 During the construction phase IWM North will need access to be maintained to the Visitor and Staff car parks daily, and will need access to the Museum Exhibition space ramp frequently at times to be agreed with the Contractor. The powers in the Order as drafted allow Trafford Wharf Road to be temporarily stopped up. IWM require TfGM to enter into an agreement with IWM limiting TfGM s powers so as to ensure that access is maintained to the Visitor and Staff car parks daily during operating hours, and that access to the Museum Exhibition space ramp can be secured frequently at times to be agreed with the Contractor. 6

7 4.9 Given IWM North s reliance on visitor numbers and their associated secondary spend, IWM also ask that TfGM supports publicity of IWM North during the construction works through marketing/poster sites at other tram stops and support through social media and additional traffic signage to ensure that visitors know that the carpark is open as usual and that despite the works that visitors can still gain access to the museum The parcel of land (3015) required for temporary access abuts the south-east corner of the building. As explained above IWM North is designed by Daniel Libeskind to reflect the themes of the Museum, the impact of war and conflict on the world today. As such it is constructed to represent three shards of the globe Earth, Air & Water. The corner of the building abutting the temporary work area is the lowest point of the Earth shard, housing displays which amongst other topics cover the Jewish Holocaust. IWM needs assurance that every step will be taken to protect and prevent damage to the architectural fabric of the building, the health & safety of visitors and the collections & displays. IWM need, therefore, to have sight of and to approve the method statements for works in the vicinity of IWM North; such method statements to describe the exact position of the works; the manner of their construction including details of excavation, positioning of plant etc. and the steps to be taken to protect the architectural fabric of IWM North and the health and safety of visitors to IWM North IWM also needs to have certainty that the utility supplies serving IWM North will be maintained during the construction works during museum operational hours. If on any day IWM North does not have a water supply it will be unable to open on that day. Any disruption to electricity and internet connection would also have serious impacts on IWM s ability to open and certainly to hold corporate events Construction work will also inevitably cause dirt and grime, which will undoubtedly cover the building and may, through air intakes, enter the building. As a museum with precious objects on open display the minimising of dirt in the atmosphere is essential. Indeed one key object a Russian Tank - is on open display outside the Museum. IWM require legal commitments from TfGM, as well as requesting that the Code of Construction Practice is revised, to address the following requirements: Spread of dirt & dust is kept to a minimum through regular cleaning up; Strategies are in place to prevent ingress of dust into the IWM North building; 7

8 IWM s external exhibit is suitably protected (following guidance from IWM staff); and Where necessary the building exterior is cleaned at the end of the construction phase at TfGM s expense. 5 CONCLUSION 5.1 IWM does not object to the principle of the Order but, for the reasons stated above, has objected to the extent of the powers the Order would give to TfGM. 5.2 For the reasons set out, IWM requests the Secretary of State not to make the Order in its current form unless TfGM enters into an agreement with IWM limiting TfGM s powers to IWM s satisfaction and ensuring that IWM s interests are protected to its satisfaction, including any agreed mitigation measures and TfGM agrees additional planning conditions on the deemed planning permission sought in conjunction with the Order. 5.3 IWM is in negotiation with TfGM with regard to the matters addressed in this Statement of Case and hopes that it may be possible to resolve its concerns by agreement. However pending agreement IWM finds it necessary to submit this Statement of Case and to reserve its right to appear at Inquiry. 5.4 IWM also reserves the right to amend or add to this Statement of Case and the grounds of its objection. 6 DOCUMENTS 6.1 IWM may wish to refer to the Inquiry Documents should it need to appear at the Inquiry into the Order. 6.2 Additional documents may be referred to in evidence if IWM is obliged to maintain its case at Inquiry. Berwin Leighton Paisner LLP 29 June