Here is the text of our formal response to Cardiff Council consultation on their proposals to build a Cycleway through from Western Avenue to Cowbridge Road East through Bute Park and Sophia Gardens
1. CONTEXT: This consultation is part of a process to implement a policy for a ‘Cycling Superhighway’. The current phase is being developed on land in the ownership of the Council – some of it part of a bequest from the 3rd Marquis of Bute – which it holds in trust for the benefit of the people of Cardiff.
2. CARDIFF CIVIC SOCIETY (CCS): CCS supports policies for sustainable movement and conservation of its natural and historic environment set out in legislation, national planning policy (Planning Policy Wales, PPW Edition 10), Cardiff Local Development Plan (LDP), Supplementary Planning Guidance (SPG) including Green Infrastructure SPG, and the Welsh Government Chief Planner’s letter (Oct 2019) requiring biodiversity enhancement in every new development to ensure eco-system resilience. We expect Council decisions to be taken in line with these policies, its duties under the Wellbeing of Future Generations Act (WFGA), the imperative of the Climate Emergency, and reduction of flood risk.
3. CCS KEY POINTS:
The diagrams and information provided about this cycleway proposal lack detail and clarity. Although, quite rightly, the Council cancelled its public consultation events due to COVID-19, it regrettably has not made any attempt to provide virtual consultation meetings (e.g. Skype).This makes it difficult to respond to certain elements, as there are many issues that are unclear.
We note that Cycleway 4 Phase 1 barely adds a single additional yard of traffic free cycling to that which already exists. Therefore we believe that the Council would be better placed to rethink Cycleway 4 so that cycleway development will add to the capacity of traffic free cycling on roads.
The area covered by this proposed cycleway is already largely traffic free and therefore safe for both cyclists and walkers. What aren’t safe are the roads – e.g. there was a road accident in Penhill Road recently, which led to a cyclist being taken to hospital. The Council needs to spend money on making roads safe for cyclists and pedestrians – not spending money on turning a Park into a road.
The proposed cycleway is routed through a public park, which is not a road. Lighting and signage, etc, is inappropriate for a park. CCS is very concerned to note yet again the increasing urbanisation of our public parks.
As it currently stands, the scheme which is proposed requires a very significant sacrifice on the part of leisure walkers, pedestrians and nature which currently use the proposed route. It does nothing to reduce motorised traffic in the city.
The reduction in the city’s green space has already gone too far; any new proposals must respect the very special characteristics of the Parks. We urge the Council to avoid ANY adverse impacts on the Parks and its many users. The local authority has a statutory obligation to enhance well-being, enhance the natural environment, and protect and improve biodiversity.
4. (i) Impacts on key historic and natural features, including the lime tree avenue, are not dealt with adequately. In particular, and in view of its importance historically and for nature conservation, the cycleway should be moved west of the lime avenue along its entire length. No mature trees or hedging should be damaged, nor the surfacing/character of a Public Right of Way adversely affected (paras 3.1.3, 3.5 GI SPG).
(ii) Sections of two walls are to be partially demolished, one near Western Avenue, the other north of the National Sports Centre (NSC) where “an existing historic wall is to be shortened and stone used to repair walls within park”. If the cycleway path between the Riding School and Western Ave is removed, then there will be no need to partially demolish the Western Avenue feature. CCS does not support the demolishing of this historic gateway.
(iii) Section at city centre end of the proposed cycleway – This does not appear to be fit for purpose. There appear to be 7 points at which the cycleway intersects with either roads or pedestrian paths. It isn’t clear whether or not cyclists have priority at these intersections. If they don’t, then there seems to be no point to the cycleway. Any cyclists using this area will simply continue to use the existing road, as it will be more direct, quicker and involve far fewer stops. It is also not clear why cyclists will take a detour to use this rather tortuous route. Coming from the City Centre, cyclists will either ride through Bute Park or use the existing Taff Trail path. Ditto cyclists riding into the City from the North. Cyclists riding up from the Bay will surely continue on the Taff Trail. Cyclists riding from the West are likely to avoid this section and enter the park to the North of the cricket ground. What evidence does the Council have about who (and how many) will use this cycleway section? A far simpler, cheaper and altogether better solution would be to give cyclists and pedestrians priority over other traffic in this area and use a 5mph speed limit.
Environmental objections to Cycleway 4 phase 1, in the context of above legislation
5. (1) Increasing tarmac along the iconic Lime Tree Avenue and in Sophia Gardens, will compromise the longevity of the trees. According to our expert from the Arboricultural Acssociation, even with a no-dig option, soil compaction will have an adverse impact on the trees.
“The ‘root protection area’ of a tree is deemed to be the minimum area within which sufficient soil is likely to be present to enable the tree to thrive – it’s calculated as being the area of a circle with a radius 12 times the diameter of the tree measured at 1.5m. For a tree with a 40cm trunk, that would be a radius of 4.8m; for a 1m tree it would be 12 metres.
The overwhelming majority of trees in the affected sections fall into the above category, and will therefore have their ability to thrive compromised by damage to delicate root systems, and their longevity seriously curtailed by the application of further tarmac. Compaction as described above also makes a tree more likely to fall during our ever increasing storms.
CCS members have noted little traffic at the Western Avenue end of the Lime Tree avenue, and, as most vehicles are travelling to Cardiff Riding School, they do so with the utmost care as they are accustomed to exercising due caution in the vicinity of horses, dogs and humans. We can see no good reason to build a cycleway and path along this stretch, as the traffic on this part of the avenue is minimal. In addition, this area is a nature “hotspot” – there is a high density of species-rich birdlife (a good indicator of biodiversity more generally) along this part of the proposed cycleway. We cannot support the building of a cycleway here. The existing road is more than adequate.
(ii) During springtime the affected area is abundant with celandines, an important early source of food for pollinators. To destroy this source of food, will adversely affect our already threatened pollinators and fail to comply with Section 6 of the Environment Wales (2016) Act and the requirement to protect and enhance biodiversity. and are protected under Section 6 of the Environment Wales (2016) Act.
The grassy areas by the trees also provide important foraging areas for the Conservation red-listed Song and Mistle thrushes.
(iii) There is a significant body of evidence that illustrates the negative impact of lighting on our vital insect/pollinator population. Even motion sensor lighting is detrimental, as the motion sensors trigger at the slightest movement. Lighting will also have an adverse impact on bats. Due to a warming climate, bats due not hibernate consistently during the winter months. In December 2019, for example, bats were seen flying at dusk and just before, on most days. The RSPB notes that artificial lighting is highly disruptive to bats’ roosts and foraging pathways and flight routes.
(iv) In the context of recent flooding, and the prospect of future flooding, given the effects of Climate Change, the wisdom of paving over more green space – from Sophia Gardens, through the Lime Tree Avenue to Hailey Park – has to be called into question.
Furthermore, the tragedy of Covid-19 has illustrated that distance working dramatically reduces congestion and pollution, and negates the need for a Cycle Superhighway. While cycling will fluctuate given the weather conditions for most people, working from home offices will provide a permanent solution.
It is clear from the events relating to Suffolk House that Cardiff Council is out of step with public opinion when it comes to protecting trees, green spaces and biodiversity.
CCS does not support this proposal.
CCS requests a (Skype) meeting with Council Officers to discuss the above before the Council make a decision about it, with a view to finding better solutions, and ongoing involvement in commenting on plans for the remaining sections of the cycle route prior to public consultation, to ensure that the Council devises ‘win-win’ solutions. CCS would prefer this approach rather than the alternatives – mobilising public opinion against the proposals and/or mounting a legal challenge.