Monday 7 September 2020

Bishopsford Road Bridge - MCC objects to planning application

Bishopsford Road Bridge is being rebuilt. However the plans fall short of Merton Cycling Campaign's expectations for active travel, and we have a number of objections to the plans.

The Council has submitted its planning application for a new Bishopsford Road Bridge (Planning Application 20/P2438). Like many Merton residents we want to see this route re-opened as soon as possible, but have to object in the strongest terms to the design of this bridge. 

We submitted our objections to the Council on 7th September. The reasons for the conviction that this application should not be approved are:

1. A primary criterion for the design of this bridge carrying the A217 over the River Wandle is to be functionally adequate for 120 years. The application gives plenty of historical information but demonstrates no careful assessment of future use patterns.

2. The design does not meet the expressed intention of the designers, as set out in the Design and Access statement. It does not provide dedicated cycle lanes in both northbound and southbound directions as stated and therefore does not cater for the demands of the modern transport system as claimed.

3. The application gives no evidence of proper consultation with the only adjoining owner, the National Trust, but makes the adjoining owner an excuse for a compromised design. Despite the National Trust accepting use of their land if the bridge is to be widened for the inclusion of cycle lanes.

4. The application does not give confidence that this very public bridge is the result of a careful design process. This must be partly expected at the height of a pandemic, but at the same time, the validity of most of the associated design decisions can be easily and immediately verified on the internet.

Merton Cycling Campaign is the Merton branch of the London Cycling Campaign, an independent membership charity lobbying for better conditions for cycling in London, it is one of the largest urban cycling organisations in the world with 11,000 members and is a participant in establishing the guidance and design standards for cycling.

One of the questions asked by the Design Review Panel on the proposed bridge was: Have Merton Cycling Campaign seen and commented on the scheme at all?

The response from the bridge design team was that Merton Cycling Campaign commented at preapplication consultation and will be invited to comment again during the planning application process.

It should be noted that this pre-application consultation was the Public Consultation on a Borough’s design that had not taken account of established Borough Policy on active travel.

Merton Cycling Campaign’s response was: ‘The opportunity for a fit-for-purpose replacement bridge for Bishopsford Road across the Wandle must surely be taken and be designed to be wider than the failed bridge in order to safely accommodate walking and cycling alongside vehicular traffic. Thus, providing a bridge wide enough to take pedestrians and a protected cycle way in both directions’.

Merton Cycling Campaign were not involved in pre-application consultation for the design submitted in this application. We obtained a preview drawing prior to the Application on August 4th and wrote to the Cabinet Member for Transport on August 7th to say that the application proposal was seriously flawed.

There follow detailed explanation of Merton Cycling Campaign objections. 

1.Future Use Patterns

There can be no doubt in a world of climate emergency that active travel will be encouraged and that it will increase in popularity. We can look to Continental exemplars of accommodating active travel to predict the transforming nature of this trend. In particular Bishopsford Road, as a major road, is ideally arranged for segregated cycle lanes both sides with ample pavements. In fact this type of provision has been promoted in UK cities since the 1990’s but the political will has to date not sufficiently prioritised active travel.

What of future use patterns responding to a climate emergency? It is clear from current trends that deliveries by bike will increase giving a ‘trucking’ aspect to cycle lanes. It is also apparent that scooters may be regulated to use cycle lanes. At the same time there is every reason to expect an increase in pedestrian activity provided pedestrians feel safe. This means demarcation of function on busy contained thoroughfares so that pedestrians of any ability can be accommodated, including the blind, without fear of encountering silent two-wheelers.

It is very pertinent to an active travel policy that a new bridge included in such a system should be wide enough to take pedestrians and a protected cycle way in both directions if it is to effectively accommodate active travel for 120 years.

2. Dedicated cycle lanes

In contradiction of its own declared desire for a designated cycle lane in both directions, this application is proposing a shared-use pavement for southbound walking and cycling over this bridge, while offering a dedicated cycle lane on the northbound side. The Design and Access statement describes a fine example of where shared-use can be effective:

‘Shared use paths separated from roads help many people make their everyday journeys safely and are also important for leisure. Many people benefit from off-road shared paths, which provide valuable opportunities to travel in a traffic-free environment, and to relax, unwind and play’

This describes the Wandle Trail but does not describe the circumstance of an ‘A’ road on a bridge over it. It is a mis-use of shared-use to think that sticking cycling and walking together is a convenient compromise. This has to be particularly true when the cyclist has an intent encouraged by a reasonable approach velocity and the pedestrian has the opportunity to slowly take in the river views east of the bridge highlighted in this application’s Design and Access statement. It is hard to read the statement ‘Schoolchildren that go to the nearby schools and those who attend the adjacent sports facility at Tooting and Mitcham hub will benefit hugely from the safer passage afforded to them’ and believe that it is referring to this particular and hazardous shared-use pavement.

The Design and Access statement says that the entire scheme has been informed by road safety reviews. It might be expected on a Planning Application for a major road bridge with a 120 year life that a formal independent safety report would be included and that it would be expected to consider safety associated with future trends. 

To understand the prevailing view of this arrangement it is necessary to refer to Local Transport Note (LTN) 1/20 ‘Cycle Infrastructure Design’ of July 2020. This claims to summarize all the lessons from Infrastructure in practise to date. It delivers principles associated with cycle infrastructure design in built-up areas:- Cyclists must be physically separated from high volume traffic, and must be physically separated from pedestrians. In fact cycles must be treated as vehicles and not pedestrians.

This clearly separates the functional difference between the off-road shared-use path experience of the Wandle Trail and an ill-advised shared-use pavement on a high volume road. 

The Planning Application design is a mis-use of shared-use that has every indication of being dangerous now and every prospect of getting even more dangerous into the future.

3. Adjoining Owner

In answer to comments made by the Design Review Panel the applicant makes it clear that any better arrangement to the compromised bridge design is prevented by National Trust land ownership to the east.

The National Trust is understandably protective in its ownership of places and properties and has a hierarchy divided into regions each with a Director responsible. In order to request cooperation in relation to the Bishopsford Road Bridge Merton Cycling Campaign wrote to the National Trust

Director for London and The South East, Nicola Briggs, who forwarded the request to the Director for London, Jim Foy, who stated that the National Trust was ‘currently working with the council to facilitate the rebuilding of the new bridge for Bishopsford Road but have not been engaged in the design thus far.’ And continued ‘ We would be prepared to consider the use of Watermeads to accommodate a wider bridge if the additional width was for cycle lanes’.

This was transmitted to Merton Council’s design team on the 15th June when it was confirmed that the legal teams were engaged in discussion. 

In such circumstances it might be expected that this application would make some reference to negotiations with the National Trust on expanding the bridge eastwards. The National Trust are named as consultees without a contact name and they are named as neighbours. They are not referred to in pre-application discussions.

If a shared-use pavement is considered to be a reasonable cheap alternative compared to a deal with the National Trust then it is beholden on Merton Cycling Campaign speaking on behalf of those who cycle, and come to that, those who walk, to make it clear that this application design is based on a dangerous false economy. Shared-use on this pavement should definitely not be an option.

The National Trust is a significant land owner in Merton and when this quite minor highway encroachment is necessary it seems extraordinary that a land area reciprocal agreement cannot be reached, as is the practise with the Mitcham Common Conservators.

4. Design Process

There is no doubt this is an urgent matter made more difficult by the pandemic. Despite that, there have been foreseeable procedural hurdles highlighted in this application that have added to the timescale. Such problems should not be allowed to force the pace of implementation to the extent that a very wrong solution for a 120 year lifespan bridge is constructed. The foreseeable procedural hurdles go from the design brief to detailed functional restraints. 

Time and resources were spent going to Public Consultation on a design brief that did not reflect Council policy, policy that had been in place some considerable time, and for a Council that has also declared a Climate Emergency hugely important - that of prioritising active travel.

The feedback from the e-mailing Design Review Panel included in this Application shows that the public consultation scheme and the subsequent scheme were both considered. The new scheme had had no public scrutiny and the Panel were expected to judge the form and functioning of the bridge.

They were told that Merton Cycling Campaign commented at pre-application consultation. Which suggests that Merton Cycling Campaign had seen the subsequent design, which is certainly not the case until August 4th.

Merton Cycling Campaign feel that there is some justification for feeling that the Design Review Panel were misled over the functional viability of the bridge design. 

With regard to functional restraints, the guidance on the appropriate inclusion of shared-use is easily accessible on the internet and clear. Local Transport Note 1/20 of July 2020 spells it out in absolute terms primarily due to the recognised potential for mis-use of shared-use on busy thoroughfares such as the A217 over this bridge.

Final Conclusion

Merton Cycling Campaign’s reason for strong objection to the bridge design of this application are given above. We recommend that this application is not approved and that urgent and immediate high level negotiations are convened with the National Trust over the minimal highway encroachment onto their land that they agree can be accommodated. If this is by reciprocal agreement so much the better but it appears to be the only way to produce a bridge design that is worthy of existing well into the 22nd century.