OP/R4.1/OBJ11 Freehold Owners of Victoria Square House, Victoria
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OP/R4.1/OBJ11 THE MIDLAND METRO (BIRMINGHAM CITY CENTRE EXTENSION LAND ACQUISITION AND VARIATION) ORDER TRANSPORT AND WORKS ACT 1992 Simon Tucker Rebuttal on behalf of the Freehold Owners Of Victoria Square House, Victoria Square, Birmingham Contents 1.0 Introduction Page 1 2.0 Impact on Pinfold Street Page 1 3.0 Impact on Victoria Square Page 3 4.0 Consideration of Alternatives Page 4 5.0 Conclusions Page 10 Appendix 1 Page 12 Appendix 2 Page 13 The Midland Metro (Birmingham City Centre Extension Land Acquisition and Variation) Order Rebuttal Proof of Evidence of Simon Tucker OP/R4.1/OBJ11 1.0 Introduction 1.1 This rebuttal proof of evidence has been prepared in response to issues raised in the various proofs of evidence as submitted by Centro. 1.2 Centro have submitted a number of different proofs which provide overlapping, and in places contradictory, evidence and for ease of referencing, the issues are covered by topic in line with my original proof of evidence. 2.0 Impact on Pinfold Street 2.1 My evidence referred (Para 4.3.2) to the fact that the width of the footway on Pinfold Street would be reduced to around 1.6m. Until evidence was exchanged, Ardstone had been provided with no scaled plans to allow this distance to be checked. This information has now been provided in the form of an autocad drawing and the sections shown at Exhibit 13 of Mr Adams Proof (CEN/P1.3/SCH). 2.2 Paragraph 5.4.3.3 of Mr Last’s evidence suggests that there will be a minimum width of 1.98m (Section EE). However, sections BB, CC and DD show 1.4m, 1.8m and 2.0m respectively. The sections also miss the pinch point adjacent to the Post Office vaults where the building steps out and the footway will be 1.6m as stated in my evidence. The 1.6m adopted in my evidence is also consistent with Mr Parkhouse’s (CEN/P6.1/TRA) assertion at Para 45 of his Proof that a width of 1.6m should be adopted. I had further allowed a reduction of 0.1m to allow for the affect that the buildings with various openings, downpipes and build outs will have on effective width. 2.3 The Tfl Guidance suggests a reduction of 0.2m for this affect and therefore it remains the case that the assessment should be based on a minimum width of no more than 1.5m. 2.4 It is noted that Mr Parkhouse adopts the same assessment methodology as I do, in making reference to the TfL Guidance. However, he incorrectly infers from the original (Centro) 2002 surveys that sufficient capacity exists. As can be seen from our own survey at Appendix 5 of the David Tucker Associates main Proof, peak flows across the SJT/56528462_1.DOC 1 11th November 2014 The Midland Metro (Birmingham City Centre Extension Land Acquisition and Variation) Order Rebuttal Proof of Evidence of Simon Tucker OP/R4.1/OBJ11 hour are some 1,275 two way person movements. This equates to an average of 21 pedestrians per minute (not the 12 – 14 pedestrians per minute quoted by Mr Parkhouse) and a likely peak of around 30 pedestrians per minute. 2.5 On this basis, the route needs to cater for a peak demand of 20 pedestrian movements per minute per metre. With reference to the TfL Guidance, Figure 8, this puts the score at C+ as confirmed in my Proof of Evidence. Figure 9 of the TfL Guidance confirms this to be “unacceptable or uncomfortable”. 2.6 The evidence submitted by Centro is further confused by conflicting references to the use of Pinfold Street by pedestrians. Paragraph 4.3.1 (Bullet A) of Mr Last’s evidence suggests that Pinfold Street will allow pedestrian access across the tracks whereas Para 4.9.4 says it will be “Tram Only”. 2.7 In either case, given the high level of flows on this identified pedestrian route, it is clear that inadequate pedestrian provision has been made, and would necessitate significant numbers of pedestrian walking along the tram tracks to use that route. It represents a deficiency in highway safety terms. 2.8 In all other cases on the route of the tramway currently under construction where pedestrian width is restricted to this level, Centro have made significant changes to the existing infrastructure or adjacent buildings to provide alternative routes. These are evidenced by the changes at the building occupied by Waterstones on Stephenson Street, where significant changes have been made to the listed building to accommodate tram movement and at Colmore Gate(as referred to at Paragraph 5.4.3.8 of Mr Last's Proof) where the route has been designed to provide an alternative pedestrian desire line through an existing pedestrian walkway. 2.9 In all cases the widths provided are significantly below the recommended widths in Appendix B of the TfL Guidance. 2.10 In order to allow safety of movement by the mobility impaired, a width of at least 2m needs to be provided as confirmed by the DfT Guidance as set out in Manual for Streets. Furthermore, the level of flows on Pinfold Street represent “high flow” as SJT/56528462_1.DOC 2 11th November 2014 The Midland Metro (Birmingham City Centre Extension Land Acquisition and Variation) Order Rebuttal Proof of Evidence of Simon Tucker OP/R4.1/OBJ11 identified in Appendix B of the Guidance. Assuming no street furniture and no interruption in flow (such as a busy pedestrian crossing) the width can be reduced to 3.3m from the recommended minimum width of 5.3m. On this basis, it is clear that at least 3.3m of clear width should be provided for pedestrian movement along Pinfold Street. 3.0 Impact on Victoria Square 3.1 The Centro evidence makes no specific comment on the impact of the proposed scheme in Victoria Square in terms of pedestrian movements or safety. My own assessment at Section 4.2.1 of the main David Tucker Associates Proof of Evidence assumed that the width for pedestrians would reduce from 17m to 3.2m. In fact, and having now received the more detailed plans in Centro's evidence, it is clear that the width will be reduced to 3.4m from the edge of the DKE (swept path of the tram to the Victoria Square Wall – Section HH). However, the detailed plans show the provision of bollards along the edge of the tram track at this location which reduces the width to 2.6m. 3.2 In the context of the TfL Guidance, this puts the average movements to a B- (50% restricted) and the peak to a C (69% restriction), which represents either “at Risk “or “unacceptable / uncomfortable” level. 3.3 In order to allow safety of movement by the mobility impaired, at least 2m needs to be provided as confirmed by the DfT Guidance as set out in Manual for Streets. Furthermore, the level of flows on Pinfold Street represent “high flow” as identified in Appendix B of the TfL Guidance. Assuming no street furniture and no interruption in flow (such as a busy pedestrian crossing) the width can be reduced to 3.3m from the recommended minimum width of 5.3m. On this basis, it is clear that at least 3.3m of clear width should be provided for pedestrian movement along Pinfold Street. 3.4 Furthermore, as identified in the Transport Assessment (Appendix C.2), the scheme will require cyclists to dismount through Victoria Square. The impact of this has not been properly assessed. SJT/56528462_1.DOC 3 11th November 2014 The Midland Metro (Birmingham City Centre Extension Land Acquisition and Variation) Order Rebuttal Proof of Evidence of Simon Tucker OP/R4.1/OBJ11 4.0 Consideration of Alternatives 4.1 Introduction 4.1.1 There is a significant amount of additional information now provided with respect to the alternative routes proposed in the Ardstone Statement of Case. These are principally provided in Mr Last’s evidence (Exhibit 16 for Option A and Exhibits 18 and 19 for Option B). These details have not been previously provided to Ardstone, nor have the wider public been formally consulted on them as part of the current proposed Order promotion. 4.1.2 Overall, the Centro submissions include no evidence which suggest the alternative routes are not feasible and, ultimately, the alternatives are only discounted for reasons of cost. No evidence has been provided to support Centro’s cost estimates for the alternative routes which are considered excessive. There is no evidence to explain why the alternative routes would be any different in scale from the Centro proposed route. 4.2 Engineering Issues 4.2.1 In the case of both Option A and Option B, the detailed designs provided by Centro provide proof of concept, in that they have demonstrated such a route could be engineered. They have however raised a number of constraints to providing such routes and these are discussed below: Option A 4.2.2 Although, for the reasons set out in 5.2.2 of the main David Tucker Associates Proof of Evidence, this is not the preferred alternative route it remains the case that it should form part of the ongoing consideration of alternatives as required by the TAG process. 4.2.3 The main constraints suggested for this route relate to structural issues on Hill Street, which are dealt with by Mr Parsons. 4.2.4 Mr Last suggests at para 5.4.1.4 that significant changes are required to the bridge SJT/56528462_1.DOC 4 11th November 2014 The Midland Metro (Birmingham City Centre Extension Land Acquisition and Variation) Order Rebuttal Proof of Evidence of Simon Tucker OP/R4.1/OBJ11 structure to accommodate visibility splays (as shown at Adams Exhibit 16).