Evidence given to the Public Inquiry in 2002
on Coppergate Riverside York
by Geoff Beacon
36 Belle Vue Street
15 April 2001
Temple Quay House
2 The Square
Public Inquiry on Coppergate Riverside York
This is a revised version of my previous evidence of 23 August 2001. The evidence
I wish to present to this inquiry to determine the Coppergate Riverside planning
application relates to the following areas:
The effect on the character of the Conservation Area, the scheduled ancient monument and listed buildings;
traffic generation and air pollution;
extension of retailing to an area outside the traditional shopping centre to a location less well served by public transport;
Proof of evidence
1 Does this Application preserve or enhance the character of
the Conservation Area, the scheduled ancient monument and listed buildings?
1.1 The application site lies in the Central Historic Core Conservation
Area. It will have a material effect on a scheduled ancient monument (York Castle)
and on the setting of three grade 1 listed buildings. The Castle car park part of the
site is probably one of the most important undeveloped spaces in a European
1.2 A report written by the Council's own professional architectural advisors
concluded that the development would harm the character of the Conservation Area.
The management of the City of York Council has subsequently rubbished this
report. The comments of these professional advisors were not reported to the
Planning Committee. Members were in fact informed in the report to Planning
Committee that that the application caused no harm to the Conservation Area.
1.3 The key comment made in that report, supported by Amenity Societies,
and argued by this writer is that the proposed development would cause
demonstrable harm to the character of the Conservation Area and to the setting of
the scheduled ancient monument and Grade 1 listed buildings.
1.4 The principal consideration here hinges on the scale, massing, and
quality of the buildings, which will occupy what, is currently the Castle car park.
The car park is clearly an eyesore and does not provide a suitable setting for the
scheduled ancient monument and Grade 1 listed buildings. In my opinion, the
Car park space should be either an appropriately landscaped open space, or the
building, whichever is constructed, should be of outstanding quality. The
application meets neither of these requirements.
1.5 So far as the quality of the buildings is concerned, I draw attention to
the fact that the Commission for Architecture and the Built Environment (CABE)
has restated its opposition to the design of the proposed building.
1.6 Perversely, English Heritage has supported this application. However,
the English Heritage member of staff that has led their input to this scheme has
no architectural design training. No trained architect from English Heritage has
to my knowledge commented on the application. The Inspector must realise
that Clifford's Tower is English Heritage's most popular attraction in the north of
England. It raises a significant amount of revenue. A large shopping scheme
on its doorstep could only increase visitor numbers and revenue. Might I suggest
that the combination of lack of architectural judgement and a financial interest
have led English Heritage to take a view of this scheme that is entirely contrary
to every other architectural opinion except that of those employed by the
1.7 I hope the Inspector will share my view, the view of CABE, the view
of the Council's own advisors, and the views of many other qualified and
respected bodies and individuals that the application harms the Conservation
Area, adversely affects the setting of the scheduled ancient monument and the
Grade 1 listed buildings, and is of insufficient architectural quality for this
2 Traffic generation has not been properly estimated and air pollution has
been grossly underestimated
2.1 There have been many flaws in the prediction of traffic flows and the
pollution they might cause. No estimate of the total traffic flow was made until
the day of the planning committee meeting that gave the approval. It is a crude
estimate (see para 201 of the report to committee) and clearly flawed (see
section 3 below).
2.2 The predictions of changes in air quality due to increased traffic (at least
those done by the City Council) do have an implied estimate of total traffic flow
but this incorrectly uses a fixed daily traffic profile measured in 1993 to calculate
total flows from peak hour flows. This assumption that future traffic flows will have
the same daily profile as in 1993 is clearly invalid - given limited roads and parking
capacity at the peak hours, the main mechanism for any traffic increase will clearly
be by peak spreading which this methodology hides1.
2.3 Since the report on this application was taken to Planning Committee, the
City of York Council has started a public consultation exercise on options for
creating Air Quality Management Zones. Piccadilly is included in all of the
Council's options. There is clearly an air pollution problem in Piccadilly now.
The application will introduce over 500 car parking spaces and a large service
area into Piccadilly. Increased provision for buses will bring more buses into
Piccadilly. This application will by any reasonable analysis increase traffic and
there will be a significant adverse effect on air quality. The Council will include
Piccadilly in an Air Quality Management Zone. How does the Council intend to
manage air quality in these zones?2 By reducing traffic?3
The Council's position and therefore their decision on this application is
contradictory and flawed.
3 The Application extends retailing to an area outside the traditional
shopping centre to a location less well served by public transport.
3.1 Some traditional areas, such as Rougier Street and George Hudson
Street have already suffered a decline in trade. Some have argued that this area
has been affected by Council policy - the previous Chief Executive of Yorkshire
Cooperatives has indicated to me that the viability of their store, now closed,
was damaged by York Council's refusal to allow car parking.
3.2 Anywhere in this area is a more accessible location for public transport
users than the Proposed development because it is near the Railway Station,
which is the better served with busses, taxis and trains that anywhere else in
3.3 The main core of shopping in York City Centre is currently between
Coney Street, Goodramgate, Picadilly and the existing Coppergate development.
There are concerns that this area could also see a decline in trade due to the
proposed Coppergate Riverside development. Indeed York Council commissioned
a study by CB Hillier Parker (the "Linear Distortion Study") to look at this problem.
The conclusion was that loss of trade will be short term. In the longer term this
lost trade will be replaced:
"Hillier Parker conclude that the proposed Coppergate scheme
will improve the attractiveness of the City Centre as a whole
and have few if any medium or long-term adverse effects on
other parts of the City Centre." (para 93 of the Report to the
3.4 It is this that causes the main logical flaw in the argument in para 201 of
the Report to the Planning Committee which states that traffic generation for the
proposed development will only be 35% of that otherwise expected because "65%
of the customers are already shopping in the City Centre". But this 65% already
in the City Centre represent the short-term "lost trade" to the other parts of the
Centre. In the medium or long-term this "adverse effect" disappears in doing so
traffic levels would rise.
3.5 In using a short-term argument for traffic flows and a medium and
long-term argument for the "lost trade" the Council minimises the problems
of Coppergate Riverside.
4 Global Warming and Climate Change
4.1 The EIA for Coppergate Riverside clearly comes under the European
Council Directive 85/337/EEC (updated by Directive 97/11/EC).
4.2 The Checklist of Environmental Components in the Guidance on
Scoping (May 1996) includes provision for consideration of both Climate,
4.3 This indicates that the effect on climate change should have been
estimated in the EIA for Coppergate Riverside.
4.4 That this is a sensible provision is supported by the fact that, if
the Climate Change Levy were applicable to traffic generated by such
developments, then Coppergate Riverside would attract a substantial levy.
4.5 This development is part of the general trend for bigger and fewer
4.6 In 1971 50% of population did comparison shopping in 200 locations.
In 1996 50% of the population did comparison shopping in 70 locations.
("Tracking the Consumer" Mark Teale, CB Hillier Parker, Estates Gazette,
March 1997). This means people are travelling much greater distances to
4.7 In the case of this development there is the objective of competing
with minor centres (eg Malton, Scarborough, Selby, Goole). The Hillier
Parker report to York City Council (the Retail Study Update) appeared
to confirm this.
" ...For example, the development of a major new extension
the Coppergate Centre in the City Centre, Coppergate
Riverside, providing 24,256 sq m gross of new high
quality prime shop floorspace, would be likely to increase
significantly the market share of durable goods
expenditure which the City Centre attracts from its
catchment area. .(para 3.2)
...Another possibility is that the cost of car usage could
be substantially increased, through rises in the real cost
of fuel, greatly increased parking charges, and/or road
tolls. This could tend to localise shopping, thus increasing
the growth potential of smaller town centres at the relative
expense of York... (para 3.4)
...It is axiomatic that it is shops that attract shoppers; and
should current proposals to provide significant additional
floorspace in the City Centre materialise, this will be likely
to reinforce further York's market share, despite rising
costs of car use. However, in the latter part of the
forecasting period, the opposite trend could begin to
occur as Government policies for transport, which are
currently embryonic start to take effect. (para 3.5)"
4.8 This seems to say that Coppergate Riverside is against
Government policies by encouraging the use of non-sustainable transport.
The EIA does not give an assessment of carbon dioxide generation. It
does not assess the contribution this scheme will make to global warming.
4.9 Global warming and climate change are real effects and issues
which the EIA should have taken into consideration. The application is
flawed and the City of York Council negligent in not taking this issue into
5.1 I have confined my comments to four specific areas. I hope I
have demonstrated that this application is unacceptable on all four points.
I therefore ask you to recommend refusal of planning permission for this
Appendix 1 - BBC News on Air Pollution
Friday, 15 March, 2002, 23:53 GMT. Pollution strangles blood supply
The volunteers breathed in a level of pollution similar to that found in urban
areas during peak air pollution times such as rush-hour traffic.
The degree of blood vessel constriction produced by exposure to pollutants
is unlikely to produce significant problems in healthy indviduals.
However, Dr Brook said that it could conceivably trigger cardiac events in
people who are at risk of heart disease.
Wednesday, 6 March, 2002, 00:07 GMT. Air pollution cancer fears grows
In 1998, an influential government committee5 on the effects of air pollution
suggested that 10,000 people a year might be dying as a result of particulate
In addition to lung cancers and heart disease, it has been linked to
asthma, and other lung and circulatory diseases.
Roger Higman, a transport campaigner at Friends of the Earth UK, said
that the sheer scale of the US research should point the way to similar UK
Sunday, 30 December, 2001, 02:50 GMT. Pollution linked to birth defects
"It's yet further evidence that pollution from cars and lorries shortens people's
lives - and exposes the government's failure to tackle this problem."
Gary Shaw of the CBCMP, who also worked on the research admitted: "We┐re
not sure carbon monoxide is the culprit because it could be just a marker for
something else in tailpipe exhaust.
"The fact that certain heart defects are turning up in the second month of
pregnancy when hearts are being formed suggests something serious may be
He called for further research: "Unlike other health factors like diet or
lifestyle, a pregnant woman has almost no control over the quality of air she
breathes - we need answers."
Appendix 2 - York Council Shopping Strategy
Many of us would find it difficult to complete any sentence that started
"York City Council's shopping strategy is ...". We would start asking questions
like "What is the council? Do you mean the officers, the executive, the
councillors?" "Do you mean their stated policies or the ones they think they
In this appendix I do not try to answer these questions but rather present
a rational reconstruction6, which explains the actions of the
Council. The council wants
The traffic consequences of these objectives can be sequenced like this
To increase economic activity in York, with an emphasis on inward investment.
To increase retail activity in the city centre7, concentrating on
areas where the Council can benefit financially.
To encourage shoppers to come to York, especially affluent ones.
To deliver the "best-quality" shoppers as near possible to council-friendly developments
1. Maximise traffic flowing into and out of York, subject to road capacity8
and, to a much lesser extent, pollution9.
2. Maximise the number of people coming in by increasing vehicle occupancy, except
where it will restrict the supply of "best-quality" shoppers.
3. Put car parks for "best-quality" shoppers next to council-friendly developments and
manage car-parking charges to ensure "wealth comes first" (i.e. the better off will
park in the more expensive car parks).
4. Make Park and Ride a premium service. Don't worry too much about other bus facilities.
Although these issues should be presented to the York Local Plan Inquiry, this
rational reconstruction gives what I believe to be a useful background to the current
Appendix 3 - Spare capacity on Three Radials
Using traffic counts from 3rd May 2001, I have estimated the spare capacity on
three of the radials likely to be used by visitors to Coppergate Riverside. I have made
estimates of the peak capacity of these roads after discussion with a professional
The estimate I have made is of the extra vehicle trips that could be made between
the morning and evening peak hours. For the inward journey I have started with the
counts for the hour ending at 10 am and ended at the hour ending at 4pm. For the
outward journey, I have started with the counts for the hour ending at 11 am and
ending with the counts for the hour ending at 5pm.
This produced the following results:
I append hourly spreadsheets.
|Extra Traffic Capacity Between Rush Hours
|Radial ||Inward ||Outward
| Hull Road ||3369 ||3016
| Fulford Road ||2682 ||2615
| Bishopthorpe Road ||3451 ||3502
1 Recently, I have obtained traffic counts for three of the radial roads into
York, which would feed the applicants site, for Thursday, 3rd May 2001. They
are presented in Appendix 3. Simply by subtracting hourly figures from peak
hour figures these figures show that there is significant spare capacity on the
Additionally, under cross-examination, the applicant's traffic consultant
conceded that price mechanisms could alter the turnover in town-centre car
parks. As I understand it, the applicants have argued that the restriction on
the number of car parking spaces together with a fixed daily traffic profile
means there will be little increase in traffic due to the proposed development.
This argument is clearly invalid.
2 Since the application was passed by the planning committee, the
seriousness of traffic pollution to the health of city dwellers has become more
apparent. See Appendix 1.
3 See Appendix 2.
4 Under cross-examination earlier in the inquiry, Roy Templeman, the
Director of Planning and Transportation, agreed that York Railway Station
was part of the City Centre. Previously, I was under the impression that
the Council were using the "sequential test" to rule out the possibility of the
Station Site being put forward as an alternative to Coppergate Riverside.
My information does, however, predate the public promotion of the "York
Central" scheme, which has a design brief that suggests some 20, 000
square metres of retail and leisure space. This design brief was, I
understand, issued in conjunction with York City Council.
5 Committee on the Medical Effects of Air Pollutants. Quantification
of the Medical Effects of Air Pollution in the United Kingdom (1998)
6 Popper, K., (1959), The Logic of Scientific Discovery, London: Hutchinson.
7 In addition to the current application, planning permission has been
given for some 12,000 square metres of retail floor space on Foss Islands
Road. Given the design brief (see above), it is likely that further planning
permission for 20,000 square metres of retail and leisure floor space will be
given adjacent to York Station.
8 York Council are to be congratulated on their work on traffic calming
but the option of reducing traffic capacity into an out of York is usually avoided.
The proposals in the Council's study in the Fulford Road radial would probably
increases traffic capacity (e.g. Zebra crossings converted to pelican crossings.)
9 The cynical are expecting York Council's proposals for their "Air Quality
Action Zones" to be no more than putting up notices asking motorists not to
travel into York on the days that pollution is above the maximum permitted. I
regard this as lip-service to a serious problem.