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«Campaign to Protect Rural England, Avonside branch Response to Bath Park and Ride Consultation October 2015 Summary CPRE Avonside is strongly opposed ...»

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Sophie Spencer


CPRE Avonside

Poole Court, Yate


Campaign to Protect Rural England, Avonside branch

Response to Bath Park and Ride Consultation

October 2015


CPRE Avonside is strongly opposed to a further park and ride facility being introduced to

the East of Bath.

It would cause serious damage to the Avon Green Belt, and be a negative visual intrusion

on the Cotswold AONB and the Bath World Heritage City.

We feel that the supposed benefits of a park and ride would in no way outweigh this damage. Park and rides of this scale and location are, for good reason, a rather outdated principle that in general can cause harm to existing public transport and increase vehicle miles travelled without necessarily reducing the demand for car parking in the centre.

Bath should be looking to the future, designing public and active transport that will be accessible to those who do not have cars, enabling those who do to leaving them at home.

‘Bus-based park and ride schemes were devised to reduce traffic congestion and pollution in towns, to make bus travel more attractive to motorists, to create space in town centres, to improve accessibility and to bolster economic development. However, schemes have been shown to generate new car trips, increase car mileage, abstract passengers from existing bus services (often rendering them unviable, to the detriment of those without cars) and increase overall car parking capacity. They may improve the appeal of the target town centre at the expense of other places. When sites become full there is a demand for more.’ CPRE Policy Guidance note, Transport.

Impact on landscape quality, Avon Green Belt, Cotswolds AONB and Bath World Heritage City CPRE believes that the benefits of a Park and Ride in the East of Bath would be marginal and short term, weighed against considerable long term environmental damage.

For a temporary benefit of a very small reduction of cars on the London Road the rural setting of Bath would be changed forever. No amount of landscaping will change the fact that a Park and Ride, combined with the impact of a floodlit car park, on any of the three sites proposed, would transform this rural setting and have a huge negative impact on its relative tranquillity and light pollution. It is even likely that the Park and Ride could attract development proposals which would result in the surrounding villages gradually merging with Bath. This would be to their and to Bath’s detriment.

We are concerned that the consultation document itself does not appear to fully consider the potential harm to the Green Belt and the World Heritage setting when it puts forward the three ‘options’ for a Park and Ride. Bath is a beautiful city and its beauty is very much tied with its setting in the Green Belt and the Cotswold AONB. We feel that the harm done to this setting is unacceptable, yet this negative impact is not made clear in the consultation. The location of Sites B and F (Mill Lane and East of Mill Lane) are simple referred to under ‘Benefits’ – in that they are outside of the City of Bath World Heritage Site. There is no mention under ‘Restraints’ the damage that sites B and F (and indeed A) would do to the Green Belt and the setting of the AONB. This is despite general earlier referrals in the consultation to the ‘Environmental Considerations’ of the sites including Landscape and Visual Effects – such as avoiding intrusion on the Cotswold AONB, and Cultural Heritage – avoiding direct and indirect adverse effects upon heritage assets.

There is no mention of impact on the Green Belt under the Environmental Considerations.

Neither is there reference to Bathampton and Batheaston conservation areas, local listed buildings, the historic canal and Mill Lane quarter.

The National Planning Policy Framework (NPPF) emphasises the importance of protecting Green Belt in planning policy, and the fourth purpose of the Green Belt as set out in the NPPF is particularly to ‘preserve the setting and special character of historic towns’. The Green Belt around Bath was established specifically to prevent urban sprawl and the merging of the city with its surrounding settlements. It provides an important setting for the World Heritage City and is named as one of the Outstanding Universal Values of the UNESCO inscription. That the consultation does not consider the impact on the Green Belt in the assessment of sites for something as significant as a large park and ride is extraordinary. It is crucial, with so much to lose, that the assessment of environmental benefits and constraints of proposal is rigorous. CPRE Avonside believes that a park and ride facility in this area would seriously damage the Green Belt. The extent that this would impact on the Green Belt does not appear to have been properly assessed. Nor is there currently enough evidence to suggest that the Park and Ride will bring the kind of benefits that would outweigh the ‘very special circumstances’ that could justify such harm to the Green Belt.

There is no clear indication in the Consultation Document as to how the ‘Environmental Effects’ that are listed will be assessed. There is no reference to a landscape character assessment, for example, although that would seem a good place to start. We would expect that given that the historic and landscape setting is so important to Bath, that the impact on this of each of the three sites would be properly and objectively assessed using well established methods. Bath is a city that has succeeded economically despite its environmental and transport constraints. This is in part because businesses, like people, are attracted by its historic status, and the beautiful setting. If we chip away at this, who knows what impact that will have, not only on the beautiful landscapes, but the very thing that gives Bath its economic edge, particularly on this side of the city – it’s historic beauty and extraordinary rural setting. Bath is unique; businesses will locate here regardless of whether there is a Park and Ride.

Contribution to Sustainable Transport Choices

CPRE Avonside does not believe that these proposals will contribute to the overriding aims of the Bath Transportation Plan, particularly the objective to ‘increase the availability of accessible public transport’. It is well documented that park and ride services often have a detrimental impact on public transport provision as these modes of transport are abandoned in favour of free parking and cheap bus services. A proposal on very similar sites has already been put forward and rejected in the past. CPRE Avonside objected then and our position still stands. There is no change to the evidence available that Park and Ride sites are not likely to bring overall transport benefits to Bath and the surrounding countryside, nor reduce vehicle miles travelled (VMT).

Rather than being put forward on the basis of fully evidenced transport solutions, this proposal feels closely related to the strategy for developing an Enterprise Area. Despite evidence of the benefits being marginal, the park and ride is often seen as a ‘carrot’ which will help attract developers to a new enterprise area. A park and ride is an easy option, seen as contributing to public transport aims, when the reality is often detrimental to public transport, increasing vehicle use and vehicle miles. From a bus company point of view, it is also an easy option - everyone in one spot to pick up.

Evidence suggests that the number of people park and ride abstracts from traffic is actually very small relative to the number of other people accessing the city by bus, car, walking or cycling yet they are expensive in terms of land acquisition (capital expenditure) and in environmental terms. They also have the ‘peak flow problem’ of running a lot of empty buses in and out of the city when there are few customers. As they are not ‘integrated’ with other bus services, these empty buses cannot be used by others; they stand alone, a sort of executive service for those with cars. The disadvantages of a park

and ride include:

 Park and ride is a system of public transport designed around those who already have cars.

 Park and ride provides free parking and subsidised bus travel to drivers, whilst those without a car must pay the full fares on local bus services.

 People with a concessionary pass receiving a ‘double incentive’ to reduce their sustainability.

 Park and rides are known to


passengers from door to door buses. This is hugely disadvantageous to those without cars, such as the elderly or young people.

What happens with an aging population, once the individual cannot drive, the door to door bus service has been undermined to such an extent that it may not exist.

Conventional Park and Ride sites increase vehicle miles travelled

Evidence suggests that conventional park and ride facilities, consisting of a single car park at the edge of an urban area, actually increase the overall VMT. Travellers are more likely to leave their homes by car if they know that car parking is available. Some travellers switch from an all-car journey to a part-car journey, but others switch from an all-public transport journey to a part-car journey.

“the observation was that an often sizeable minority of users had changed mode of travel from public transport-all-the-way to park and ride, rather than from car-all-the-way to park and ride. As the park and ride sites were located at the edge of the city, some of the trips now made by car as far as the park and ride site, would be relatively long ones, of perhaps 15-20 km. This means that only relatively few public transport users with a car available choosing to transfer to park and ride would be necessary for the reduction in traffic in the town centre to be more than compensated for by the growth in traffic outside the urban area.” (Stakeholder perspectives on the current and future roles of UK bus-based Park and Ride, Meek et al 2009, Journal of Transport Geography) Park and ride facilities still have an enduring positive image with policymakers; however, more recent empirical studies have challenged the assumed benefits of P&R schemes (‘Where to Park’? 2014, Clayton, Ben-Elia, Parkhurst, Ricci):

 Park and ride schemes simply displace traffic issues, rather than solving them.

 They generate more car trips through increasing accessibility of urban centres.

 Park and rides encourage greater car use through ‘abstraction’ from traditional public transport (P&R users are drivers too!).

Parking policy is a tool to strengthen the vitality of urban centres in the face of competition. Increased capacity and reduced price is therefore promoted despite negative implications for traffic.

Park and ride does not reduce traffic into the centre and periphery of Bath Conventional park and ride reduces traffic within an urban area at the expense of generating additional car traffic outside the urban area. Furthermore, a park and ride essentially provides additional car parking on the periphery of a town or city at a time when overall transport policy is to restrict parking as a way of reducing traffic. Unless the parking spaces in the centre are reduced by a similar number there will be little traffic reduction into the centre as those freed spaces will be taken by someone else; and the congestion will remain. This would be compounded by increased car access to the periphery which can be ill afforded given that peak-time traffic already tails back down the A4 Batheaston bypass.

The concept of park and ride came into being in the 1970s in a transport policy environment when demand management and traffic reduction were not on the agenda.

Transport policy has moved on, yet there appears to be an irresistible urge to complete the ring of park and rides around Bath, even though this is a totally outdated policy in the current context of congestion charging, demand management and restrictive parking.

Other work done by the Centre for Transport and Society looking at city centre parking and parking in the park and rides showed that a lot of city centre car parking spaces are taken up by people who drive less than 2 miles, in other words they live in the city and in some cases could walk and cycle, but are unlikely to use a park and ride. Changing their behaviour could have as much impact as a park and ride in making more parking available to the people who, for example, work in the new enterprise area. This is just one example of other initiatives that could be effectively utilised to make more parking available in the city centre. They are less vote winning and often they are more difficult policies to implement, but effective. Does B&NES Council itself have a travel plan that encourages its employees to travel to work by means other than the car?

Public, Private or Sustainable Transport?

It is no longer reasonable to suggest that Bath’s economy is dependent on increasing car accessibility. It is important to encourage people to access Bath in different ways, by improving public transport and possibly having much smaller, more informal, visually nonintrusive park and rides further out on bus routes with fast and frequent services. These could, for example, use existing underutilised car parks associated with sports grounds, pubs etc. Smaller investments that make the walking and cycling environment more attractive will maintain the very things that attract residents and tourists to Bath. There are a number of people who do already bicycle into Bath from the eastern settlements like Batheaston but there are considerable barriers, that could be overcome, which prevent people except for the most experienced cyclists from using their bikes.

An additional Park and Ride to the East of Bath makes car access easier; which is the reverse of the overall aim of the local transport plan. Perhaps if it were practical to restrict use of the Park and Ride to people who live in a dispersed rural fashion or are without a door to door bus alternative there might be an argument to support it.

Relative cost

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