17/06459/P; Land of Former Post Office Depot, Cattle Market Road, Bristol BS1 6QW
Outline application for a new mixed use University Campus (Use Classes A1,A2,A3,A4,A5,B1(a),D1,D2) to comprise of up to 82,395sq m (GIA) of floor space including up to 1,500 students beds with all matters reserved except access. Alterations to Cattle Market Road & provision of an Energy Centre (to consider Access).
While I support the principle of making use of a derelict site and the general approach to transport taken by the University (including the proposals for minimal parking provision on site and promotion of walking, cycling and public transport) I am concerned that the scope and quality of the Transport Assessment submitted with the application isn’t sufficient, particularly with respect to off-site parking impacts. As such, the applicant has not demonstrated that the application complies with Development Management policies DM2 or DM23, and the application should not be granted consent until further assessment is carried out.
I would expect an analysis of parking demand and parking surveys to be carried out as part of the Transport Assessment, but this hasn’t been done. The only references to off-site parking impacts are at Section 4.5 which states “A parking study will be carried out at the reserved matters stage. This will be a detailed review of the on-street and off-street parking supply, restrictions and usage surrounding the site'” and Section 8.2.3 which states “BCC have stated in Scoping Discussions their concern that making the site car-free will transfer the parking demand to nearby streets. The Travel Plan Framework (TPF) will set targets, which aim to prevent this from happening. These will be monitored through ‘before and after’ parking surveys and potential remedial actions will be taken if these targets are not met”.
Taking the first of these points, treating parking impacts as a reserved matter is not an acceptable approach. The level of parking impact on surrounding roads will be a function of the land uses and development quantum permitted through the outline application, and any off-site mitigation necessary to address these impacts would need to be secured via the Section 106 agreement at the same time that any outline permission is granted. The scoping minutes included at Appendix A of the TA seem to suggest that the decision not to include any assessment of off-site parking demand is purely driven by the applicant’s programme (‘CM stated that it would not be possible to carry out parking surveys to establish the baseline until mid to late September due to the University holidays, which meant that it would not be reported in the planning application’) but this should not be justification for not carrying out the proper analysis.
The second point is the question of whether parking impacts can be managed through the Travel Plan. I cannot see how this is a robust approach – the Travel Plan will contain targets which will ‘aim’ to prevent overspill parking, but the measures proposed to help achieve these targets are relatively generic and should be being done by the university as a matter of best practice in any event. No detailed consideration is given to how progress against the targets will be monitored (if you’re carrying out parking surveys after the development is occupied, how do you distinguish between cars that are parked on street that are linked to the university and those that aren’t?) or what happens if targets aren’t met – the Travel Plan won’t have the ability to implement off-site mitigation on the public highway, and this reinforces the point that the analysis has to take place now.
Finally, it is important that if this analysis is carried out, that it is done on the basis of realistic trip generation and modal split. Firstly, I’d note that no detail of any of the data used in chapter 7 of the TA has been provided as an appendix as I’d expect, which makes analysis of the information difficult. However, it has been assumed that no trips will be made to or from the site by car. I’d suggest that this isn’t realistic – as an example, there is very limited on-site car parking for the existing university at present, yet there is a 27% car mode share for staff travel to work. Similarly, the trip generation has been based on an office in Bristol which accommodates more than 200 staff – despite only having 20 car parking spaces, it still records a car mode share of 20%, with the remaining cars presumably parked on street or in nearby public car parks.
Student mode share has apparently been based on surveys of the existing students, but I would be interested to see the sample size as the results seem slightly suspect. Table 7-1 suggests that no students in any of the Stoke Bishop halls drive, and only 12% walk – things might have changed since I was a student there, but the number of students walking across the Downs each morning suggests maybe not. It is also important to note that just because students don’t drive from halls to campus, it doesn’t mean they don’t own a car – parking surveys were carried out as a condition of planning consent for changes to Hiatt Baker hall (12/01954/F) and identified overspill car parking on residential roads around the Stoke Bishop campus. I’d note as well that the TA references Birmingham and Edinburgh university as being representative comparisons for the new campus due to their proximity to rail stations – Birmingham has a 38% car mode share for staff, with overall more than 500 staff or students indicating that they park on residential streets around the campus (https://intranet.birmingham.ac.uk/has/documents/public/UoB-Report-2016-FINAL.pdf). Although the dataset that has been used for Edinburgh university is less clear, this report (http://www.docs.csg.ed.ac.uk/EstatesBuildings/Transport/Reports/TravelSurvey2013.pdf) suggests that 15% of staff and 5% of students travelling to the city centre campuses do so by car.
I would lastly note that for arrivals weekend, the university appears to be dependent on the Bristol Arena car park (Section 5.4). Given that this doesn’t currently exist, isn’t under construction and isn’t in the university’s control I would expect that an alternative strategy is developed, even if it is secured by Grampian condition. There is also no analysis of spare capacity on either public or park and ride bus services to see whether the predicted 580 peak hour bus trips can be accommodated.