As part of our ongoing planning work Birmingham Friends of the Earth responded to the latest Reserved Matters Planning Application for the redevelopment of New Street Station (otherwise known as ‘Birmingham Gateway’). The concerns and suggestions that we raised in our response are in the excerpt from our letter below:
BFoE New Street Station Reserved Matters Planning Application Response
We welcome the proposal to substantially redevelop New Street Station, however, we would like to see the proposals meet a high level of environmental standards. As such, we have several concerns and suggestions to raise. Many of these items we raised in response to the outline application, of which some were implemented as welcome planning conditions, and feel that this reserved matters application should contain a great deal more detail about these elements given the level of integration required for some of the items. These are as follows:
Water Use & Disposal
We also welcome the inclusion of the planning condition covering rainwater recycling, attenuation and green roofs, but again would like to see more detail of these elements in the proposals. The roof to the New Street Station/Pallasades building is quite expansive, and whilst some of it is used for service access, there remains a great deal of unused surface area. This roof area could be covered with a green roof which are proven to reduce rainwater run off by absorbing rainwater, storing it and slowly releasing it into the rainwater disposal system; effectively providing natural attenuation. Additional benefits of such a green roof would also include; air and noise pollution reduction, carbon sequestration, a wildlife habitat, and a more pleasant outlook for the many buildings that overlook the roof, including the two proposed towers on the site when these complete as part of Phase 2.
Energy Use & Generation
Whilst it is stated in the planning documentation that the building does not need to conform to Part L of the Building Regulations, we are pleased to see that Network Rail’s aspirations are to meet these standards voluntarily and the inclusion of some BREEAM assessment, however, we feel the building should strive to meet the highest standards possible by achieving a BREEAM ‘excellent’ rating under the 2008 evaluation system (formally ‘very good’ under the earlier evaluation system).
The use of CHP (Combined Heat & Power) is included in the planning conditions, and we would like to see more details of this and its eventual implementation. We feel this would be a very suitable technology for use in a development such as this, which features a wide variety of uses and therefore could be expected to have a relatively constant requirement for heating/cooling, hot water and electricity. Indeed, if a suitably sized CHP unit were used, the unit could be connected to the other city centre CHPs to form a city centre wide district heating network. In addition, whilst most CHP units are powered by natural gas, it is entirely possible to have a CHP powered by biomass (such as wood pellets), which would help reduce carbon emissions further. These are usually sourced locally (thus helping local business and reducing transport emissions and costs), and have the cost advantage over gas of being available at a relatively stable price historically.
Resource Use
We are pleased to see that the proposals seek to largely retain the existing basic fabric of the building, helping to reduce resource use and make use of a building that is still in a good structural condition. We would also support the sourcing of materials and labour locally in order to reduce both embodied energy in materials, and travel emissions from workers, that was recommended in the original ‘Socio-Economic Impacts’ report in section 14.4.12. We feel this policy along with other suggestions raised in the planning documentation that make the proposed development more environmentally sustainable should be implemented and be included in the planning conditions of any approval. These including; use of sustainable resources, FSC certified timber, recycled materials, materials with low embodied energy, use of environmentally unfriendly compounds avoided, and the following of the BRE’s (Building Research Establishment) Green Guide.
Socio-Economics
Section 14.4.12 of the original ‘Socio-Economic Impacts’ report stated; “placing of labour and supplier contracts locally rather than regionally or nationally would ensure maximum economic benefit to Birmingham”. This policy should be carried forward and commitments to it made. We would also support the local recruitment of staff for the retail uses within the development. The original ‘Retail Policy Statement’ stated that; “retail provision in Birmingham is predominantly mass market”, and PPS6 states that city centre developments should be; “enhancing consumer choice by making provision for a range of shopping, leisure and local services, which allow genuine choice to meet the needs of the entire community, and particularly socially excluded groups.” Given these facts we would like to see a significant percentage of the retail space in both the remodeled Pallasades shopping centre and station concourse allocated to local and independent businesses. This would help to provide a wider and more varied choice to consumers, directly help and encourage local business, and provide a ‘Best of Birmingham’ introduction to visitors arriving at the station.
Transport
As previously stated we generally welcome the redevelopment of New Street Station, as this will undoubtedly lead to an improvement in rail services and a better experience for rail users, which will increase rail usage, and hopefully wider public transport, in Birmingham.
We are very disappointed with the proposed level of cycle parking, being that there are only to be 26 cycle stands, giving a maximum of 52 cycle spaces. Currently there is a large under provision of cycle parking at the station (which we as a group receive a great many and regular comments and concerns about), and whilst the proposals are an improvement on the current situation, they fall significantly below what we would expect to see in a high profile modern transport hub, which we feel should be remedied. As a comparison London Euston station has 100 spaces, Leeds station 124 spaces, Liverpool Lime Street 200 spaces, and Bristol Temple Meads 340 spaces. To further this point if the building were solely an office building then the council’s requirements of 1 cycle space per 400sq.m of floor space, the whole complex would require 272 cycle parking spaces. Whilst the building is not an office building, it is a major transport interchange and destination in the centre of England’s second city with 140,000 people passing through the building every day, so we would expect a provision more along these lines.
The planning documents state that there is space available for additional cycle parking and if demand proves more is required then more can be added. However, our own experience over many years is that nothing is done about this situation when it arises, despite many letters of request and complaint to Network Rail. This can be evidenced by the many complaints and concerns that come BfoE’s way as a result of this inadequate situation and a lack of improvement in it. We would urge the council to demand a greater cycling provision from the beginning rather than taking a ‘wait and see’ approach. In addition to standard cycle racks, we would be keen to see a significant amount of secure cycle lockers/secure storage facility, which would be especially useful to people leaving cycles for long periods of time. Another amenity that would benefit cyclists would be the provision of showers and changing areas as part of the toilet facilities, a feature often found in many main city stations in Europe. This would not only be of use to cyclists, but also to rail travelers who wished to freshen up on arrival, or before a long journey. In addition, cycle access to the station should also be improved, with the provision of clearly marked and segregated cycle lanes.
We also have concerns about the pick-up/drop-off zone in the proposals. A very narrow footway is currently shown on the plans in this area, and bizarrely there appears to be no direct access from the pick-up/drop-off point into the ‘unpaid concourse’, hence forcing pedestrians to walk around the building to either Stephenson Street or Queens Drive on the narrow footway which is both inconvenient and confusing for visitors.
Conclusion
Whilst we welcome the redevelopment of New Street Station, we feel the proposals have some way to go before they can possibly match up with the rhetoric about sustainability that is often quoted by those involved with the project. We feel very strongly that this project should be setting an example of sustainability to other developments and the general public, making a strong positive statement to all that use and pass the station, of Birmingham’s commitment to a sustainable future.
