Westcombe Society Response to London Olympic Planning Application for Greenwich Park
The following is the text of a letter sent to Greenwich Council Planning Department by Gordon Baker, Chair of the Westcombe Society in response to the Planning Application submitted by the London Organising Committee of the Olympic Games for permission to hold a test event in Greenwich Park in 2011 and Olympic Equestrian events in Greenwich Park in 2012. The only changes to the text are found in brackets and clarify points for readers of this Web page.Although we are very grateful to you (Greenwich Council Planning Department) for the slight extension in the deadline for responses, we still contend that the time allowed is unreasonably short for small local voluntary societies, let alone private individuals, to assimilate and comment on such a lengthy, complex and important dossier on a topic which has aroused so much local controversy, especially when that time has straddled the Christmas and New Year holidays.
I attach for your action the Society's formal response to the application (attachment follows immediately in this Web page). This covers the assurances which LOCOG has given and other key points where the Society finds that the application is still unclear or unsatisfactory and to which we believe that effective additional specific conditions should be attached.
Our submission concentrates mainly on access to the Park and transport arrangements which are of the most vital concern to our members and all who live or carry on business in the Westcombe Park area. At an information meeting jointly arranged by this Society, the Blackheath and Greenwich Societies and the Friends of Greenwich Park in September of last year more worry and incredulity was expressed from the floor about the perceived inadequacy of the transport arrangements in the light of local experience than about any other aspect of the Greenwich Park Olympics.
We have also focused on the Arena, where information and consultation has been tardy and less adequate than the extensive information and consultation accorded to the Cross-Country course. Attention has also been drawn to a number of specific concerns about the Park itself to which we believe that conditions should be attached. So far as the Park is concerned, however, we have been guided by and broadly support the observations of the Friends of Greenwich Park, whose expertise we greatly respect. Detailed comments on these points are set out in a separate Annex, which should be appended to and considered together with our response.
Finally, we have commented about the inadequacy of information and assurances on the legacy of the Greenwich Park Olympics, about which many of our members remain confused.
Our submission has been drawn up in consultation with the Friends of Greenwich Park and the Greenwich and Blackheath Societies, to whom copies will be sent. I am also sending courtesy copies to Neil Smith and Margaret Harper of LOCOG.The full text of the submission follows, with the Annex supplied as a separate Word document.
PLANNING APPLICATIONS REFERENCES: 09/2598/F & 09/2599/L
GREENWICH PARK OLYMPICS (Applicant: LOCOG)
WESTCOMBE SOCIETY RESPONSE
The Westcombe Society acknowledges LOCOG's comprehensive and painstaking approach to the application. We also welcome the extensive consultation by LOCOG which preceded the application, particularly with this and other local amenity societies, and the changes which have been made to the plans as a result.
We note the assurances that LOCOG has given to protect the environmental and historical integrity and character ofGreenwich Park, ensure prompt and complete restoration of the Park after the Olympic events and minimize disturbance to park users, local residents and businesses. We urge the Council to incorporate LOCOG’s assurances as binding conditions if planning permission is given.
We also propose that the Council should consider imposing the following additional conditions to address the concerns summarised which have arisen where the application appears to us to be unclear or otherwise unsatisfactory:
ACCESS
A revised and detailed plan must be produced showing clearly how pedestrians and cyclists may transit the Park during the Test Event, the construction phase, the Olympic events themselves and the subsequent dismantling and restoration phases, with a view to preserving reasonable transit access for as long as possible, especially during the school holidays. Alternative routes should be provided during the events for pedestrians and pedestrians between the Westcombe Park area and Greenwich that avoid Romney Road
See the explanation given in Section A of the linked Annex.
ARENA
Detailed plans for the Arena, both stands and Arena itself, should be re-submitted with more detail for public consultation and reconsideration by the Planning Board at a later date. A revised design for the Arena should be produced which:
improves the sight lines from the Queen's House so that the Wolfe Statue and Old Royal Observatory are more clearly visible ;
shows clearly how the Arena will impact on the view from the Wolfe Statue;
demonstrates how the visual impact will be minimized during the construction and dismantling phases;
sets out a firm proposal for the performance area surface of the Arena and demonstrates what impact that surface is likely to have on the ecology and use and enjoyment of the grassland from the run-up to the Test Event to the dismantling of the Arena after the events are over and the restoration period beyond.The final decision should not be left in the hands of Officers.
See the detailed explanation given in Section B of the attached Annex.
Additional Conditions should also be imposed requiring satisfactory explanations and assurances about other points of concern to the Society regarding the Park where the assessment is either inadequate or unclear.
See the detailed explanation given in Section C of the attached Annex.
TRANSPORT ASSESSMENT
1. Estimates of Demand
A more detailed assessment must be submitted, following re-validation of the statistics and local consultation, showing clearly how public transport will cope, especially on Cross-Country day.
The transport estimates seem to us to be over-optimistic and, in some cases, challenging to local experience. The basis of some of the assumptions is unclear or questionable. No breakdown of demand by mode or route is given.
The detailed assessment should demonstrate (for both arrival and departure) sufficient public transport capacity, in addition to that required for other users. It should include appropriate margins to allow for at least minor incidents, for deviations in modal split from that anticipated, and for variations in the rate of flow. If transport capacity is insufficient, numbers should be strictly capped.
We are particularly concerned about the estimated attendance of 75,000 spectators on Cross-Country day. That estimates takes no account of the unspecified number of members of the Olympic family, support staff, media personnel, security and emergency personnel, vending and catering staff and others who will also be in the Park on that day, of whom a significant proportion may also be expected to be using public transport.
While we are not qualified to comment on the impact that such numbers may have on the Park itself, we share the concerns that the Friends of Greenwich Park and others have expressed about it. But we have very serious doubts whether public transport will be able to handle so many passengers without causing extreme congestion and delay and consequent inconvenience to other travellers.
The assessment suggests that the experience of the London Marathon indicates that such numbers can be safely and conveniently managed. But far fewer passengers are involved on Marathon day, which is always a Sunday when there are direct scheduled train services from Charing Cross on the Greenwich line and when other passenger traffic is usually fairly light
2. Blackwall Tunnel
A comprehensive contingency plan must be submitted for the possible closure of all or part of the Blackwall Tunnel.
The tunnel is a notorious bottleneck. Recent experience has shown, not for the first time, just how much traffic disruption is caused throughout the area if it has to be closed. Alternative contingency routes will be needed for the Olympic Family and due allowance made for the probable impact on local traffic.
3. Rail Services
The assumptions about rail travel must allow for the recommended spectator arrival times of 90 minutes before the Arena events and 2.5 hours before the Cross-Country (8.2.5), as well as the lack of current direct rail services from Charing Cross station to Greenwich and Maze Hill stations and consequent congestion atLondon Bridge station. Special trains must be provided on the Greenwich line.
The recommended arrival times will cause most spectators travelling by rail from Central London to do so in the rush hour. They are likely to want to take trains from Charing Cross station. But, although paragraphs 5.4.8 and 5.4.9 imply that the current SET timetable has been taken into account, there are no longer any direct trains from Charing Cross on the Greenwich line.
Unless they take direct trains to Blackheath station (at present only 4 between 0730 and 0930) spectators will therefore have to change trains at London Bridge station for the Greenwich line. This would be bound to create congestion, confusion and possible safety hazards as they mingle with numerous other spectators changing from the Underground and commuting rush hour passengers, many of whom also have to change trains at London Bridge. Nor does any allowance appear to have been made for the possible consequences of the major works due to be carried out at London Bridge in the run-up to the Games.
A similar problem may arise on return journeys as there are no direct evening Greenwich line trains to Charing Cross until 2135. Alternatively, it may mean that more spectators may choose to travel via Blackheath than has been assumed in the assessments for Arena days. The obvious solution is to lay on special direct trains between Charing Cross and Greenwich and Maze Hill.
The recommended arrival times are also likely to add to rush hour congestion on incoming Greenwich line commuter trains from the suburbs and Kent.
4. Coach Services
A clear assessment should be given of planned coach service movements.
The present assessment does not give sufficiently detailed estimates of the expected volume, frequency or direction of coach services, including time spent at the main set down and pick-up points on Charlton Way (see Figure 3.1 for modelled junctions), nor does it say on what average size of coaches the estimates are based. The assessment should show whether Charlton Way offers adequate capacity to avoid a backlog that might block local roads or the A2.
5. Park and Ride Services
The demand for and impact of Park and Ride Services should be re-examined.
Better information is needed on the assumptions made in the assessment. More spectators may choose to use Park and Ride Services than has been estimated.
If so, the impact on local traffic and pedestrians may need to be re-assessed.
6. Shuttle Buses
A similar re-examination should be made of shuttle bus services.
Here again demand may have been under-estimated, especially in bad weather.
The proposed arrival route seems likely to add significantly to local traffic congestion, as well as taking a great deal of time. It is not clear whether the same route will be used for departure. No provision appears to have been made for shuttle bus services serving Blackheath station. Nor is it clear to what extent scheduled bus services may be increased to cater for spectators and relive pressure on other travellers.
8. Taxis and Private Hire Vehicles
Spectators should be discouraged from using taxis or private hire vehicles.
The taxi rank at Greenwich station has very limited capacity. The mini-cab depot at Blackheath station has rather more capacity, but the entrance/exit can create serious traffic flow problems if extensively used.
9. Disabled Access
More details should be given of the arrangements for disabled access following consultation with appropriate local organisations. Special attention should be given to the inadequate provision for disabled travellers at Blackheath and Maze Hill stations, including the installation of a disabled access on the down platform at Maze Hill (ideally as a permanent legacy).
We welcome the plan to provide designated parking for Blue Badge holders but details of the planned capacity and proposed location are not given. Adequate detailed plans for disabled spectators should be drawn up in consultation with appropriate local organisations, recognising that not all disabled people are Blue Badge holders or wheelchair users. The walk from Blackheath station to the Park would be too far for many people with restricted mobility.
At the moment, the up platform at Blackheath station cannot be used by the wheelchair-borne and access is difficult and potentially dangerous for others with restricted mobility, especially when the station is very busy.
Similar problems arise at Maze Hill station. The only exits from the down platform require alighting passengers either to climb up and down a footbridge or make a long diversion involving walking up the steepest part of Vanbrugh Hill to Westcombe Park Road and beyond. This is impossible for disabled travellers. A disabled access ramp is badly needed there and would make a good permanent legacy of the Games.
9. Parking Restrictions
More information should be given on additional local parking restrictions proposed, following local consultation.
We welcome the statement (paragraph 4.3.28) that people and businesses should not be inconvenienced in going about their normal activities by traffic congestion. That partly depends on traffic flow planning, but this has also to be reconciled with the additional parking restrictions envisaged by paragraph 4.15, the final bullet point in paragraph 5.6.8 and paragraph 7.16. Westcombe Park residents and businesses will be especially vulnerable to overflow traffic and indiscriminate parking unless adequate measures are worked out in consultation with them and adequately enforced. So far local consultation about this has been insufficient.
9. Romney Road
The impact of present plans for use of Romney Road by spectators should be re-evaluated. To reduce pressure rail-borne spectators from both directions should be encouraged to use Maze Hill station.
We foresee considerable difficulties in the present proposals for channelling pedestrians in Romney Road and enabling them to cross it. Everything should be done to minimise the disruption to buses and other essential traffic, but the Romney Road spectator crossing analysis (Section 12) seems to us to be unduly optimistic. It makes relatively little allowance for varying walking speeds and it does not consider the probable consequences of the need to filter into the other stream of pedestrians coming along the bus lane. The proportion of time allocated to pedestrians during each 2-minute signal cycle may have to be increased, thus further restricting traffic flow. Estimates should also be given of return pedestrian flows when the events are over. If possible, the bus lane should be re-opened outside of the arrival and departure times (during the middle of the day as well as early morning and evening).
Channelling more spectators through Maze Hill station would seem an obvious way to relieve pedestrian pressure on Greenwich Town Centre and Romney Road.
10. Public Information
Draft travel information leaflets should be submitted for approval by the Council following local consultation.
It essential that all spectators should be given comprehensive but user-friendly guidance on all aspects of travel to and from the events in good time. After local consultation and approval by the Council, an information leaflet should be issued to all ticket holders and relevant travel agents.
Similarly cleared leaflets tailored to the needs of local residents and businesses should also be issued in good time to all households and business premises in the Borough. These steps should be accompanied by wide publicity.
LEGACY
More adequate information and assurances should be given about legacy proposals.
The four local amenity societies submitted a list of legacy proposals, including co-ordinated improvement of the Blackheath Gate, to LOCOG in January 2009 but have still had no response. Local people are confused as to what may be expected locally from the Olympic legacy and how to bid for it.
Westcombe Society
13 January 2010