Bath Spa Station - what are my objections and why?

There seems to be a belief that my objections to the station are all to do with the history of the ramp. That isn't the case. It has to do with efficiency. I was trained as a systems analyst, and I am just horrified at the mess that is going to be created if these plans go ahead. I know many people are saying that the ramp looks horrible - that's true, because it's been allowed to look horrible - but it could look splendid if it were landscaped and planted. The pictures that you see of this lovely square assume that behind the ramp there is ashlar stone. Given that Brunel was working to a very tight budget, that is unlikely. In fact, the very latest drawings seems to acknowledge that - they now talk about Bath Stone facing.

While talking about the square, I'm fascinated by all those people who say: And now Brunel's vaults will be revealed! There's only one thing wrong with that - they were never meant to be revealed. It's a bit like saying - we think Auntie looks a bit old-fashioned and shabby so we'll rip off her clothes and her underwear will be revealed! Put like that, I hope you can see that what is proposed is pretty silly on the aesthetics front.

Others have said that I'm exaggerating the problems. Well, I took a presentation to the Department for Transport to see if they thought I was exaggerating. They did not - in fact, they confirmed that they had raised many of the points that I had raised and not received any satisfactory answers. There have been no flow measurements until very recently - and that was as a result of one of my Powerpoint slides which simulated what I thought the flow would be like. Under the plans which I believe will to be thrown out, there would be people milling about at the top of the stairs as people using the lift - including wheelchair users, those with luggage and those with cycles - tried to get to or from that door just at the top of the stairs. It's the door on the left in my picture. I hope you can see now why the DfT and the ORR are not very impressed.

I'll try to keep this blog up to date, but for this first entry, I'll copy the report I made to the Office of the Rail Regulator - at their request - and I think that lays out very clearly all my objections and my suggestion for an alternative. It doesn't mean that there aren't other satisfactory alternatives,and it doesn't mean the ramp has to stay. All I'm saying is - what is proposed is wrong.

Meanwhile, the site where you can see the plans is http://idox.bathnes.gov.uk/WAM/showCaseFile.do?appNumber=08/04795/COND Incidentally, some new drawings have just gone up and these appear to show that there will be railings between the platform and the terrace of the unit through which you will have to leave in the event of an emergency. That's fine, assuming that the fire alarm goes, because a gate will swing open, but if the alarm does not go off in Unit 5 - say, for example, there's a disturbance, which has happened before now - everyone will be penned on the platform, with the stairs or a small lift the only way off. Anyway, here's my report. More later.

Submission to the Office of the Rail Regulator.

Bath Spa Station - a report.

Issues raised by the present plans.

Introduction

I have laid out the problems created at Bath Spa Station by the new proposals under three headings – Safety, Passenger Comfort and the Disability Discrimination Act. However, Section 1 gives the background to the complete picture, and Section 5 gives a possible solution, so that no one can accuse me of being purely negative.

1. The background picture.

1.1 History.

In fairness to FGW, Multi and B&NES, the roots of the problem lie with the original design by IK Brunel. The station lies on a cramped site, the lines are on the first floor rather than at ground level, and to make matters worse, at each end the lines cross over the river, so in the event of a major disaster or accident, there is no easy egress from the station platforms except by the ramps which now exist on both sides.

Almost immediately, the station was identified as being inconvenient. The ramps were used for goods traffic and for loading carriages on to the rail – a kind of early Motorail. There were two large lifts, one on each side, and one of these, on the down side, is to be restored. This is also the side which is to keep the ramp. However, on the up platform, it is no longer possible to do this, as the space where the lift came out on to the platform is now given over to a sushi restaurant called Dashi.

1.2 The present situation

Over the years, the ramps have become convenient exits for people arriving by train, especially with the long 125 trains. Many cyclists take their cycles up there, some to go on the train, some to leave them there as they go up to London, to be collected in the evening. This is a secure place for cycles to be, under cover of the canopies.

Many people arrive at the platform when the taxi brings them up the ramps to the platform. This is particularly useful for the disabled, but also convenient for the elderly, those with heavy luggage, and people with small children in pushchairs. There is disabled parking under cover beside the platform and dedicated spaces for emergency vehicles. If anyone needs to be stretchered off the platform, that can be achieved easily. If a head injury is involved, the “scoop and run” technique can be applied.

Above all, the ramps are obvious and uncluttered emergency exits. Bath Spa Station is a very busy station by any standards, given that it has only two platforms, and at rush hour it is almost overloaded. Nearly five million people use the station every year, compared with about seven million at Bristol Temple Meads, and these are spread over fifteen platforms. At rush hours, those trying to get off the train can hardly get on to the platform.

The other access to the platforms is by flights of stairs. Those to the down platform go straight up, but those to the up platform have a bend in them about halfway. Accidents have occurred on these from time to time, due to the press of people.

1.3 The Plans

The plans are to remove the ramp to the up platform, and to build a commercial building at the top level where the present car park is. A lift is to be provided on each side. On the down platform, as previously noted, the old lift shaft is to be used, although the promised restoration of the old lift has been watered down. On the up platform, the plans at time of writing are to have a lift with an exit from a lobby right at the top of the stairs.

1.4 Additional Points.

It should be noted that the building is listed Grade 2*, so major changes are unlikely to be permitted, especially as Unesco has considered the possibility of putting the whole of the old GWR line on the World Heritage List. At present this plan is in abeyance, but may well be revived. Within the station, this limits what the developers can do. However, English Heritage were persuaded to agree to some significant alterations in the name of safety and customer satisfaction, and this included the removal of the ramp to the up platform. This part of the station was taken from Network Rail under a CPO. It should also be noted that, at the time, Network Rail had concerns about passenger safety, but the council’s lawyers stated:

Recent discussions with Network Rail have made substantial progress and I am confident that the outstanding issues between my clients and Network Rail will be resolved. None of these issues relates to the need for the CPO in order to ensure that those elements of the Scheme that are to be carried out on Network Rail’s land can be achieved. Nor do the outstanding issues relate to the detailed design of the Scheme, rather they concern commercial matters and the need for Network Rail to be satisfied that the Scheme will not adversely affect the safe and satisfactory operation of the Station.

It is my contention that the scheme does indeed adversely affect the safe and satisfactory running of the station.

2. Safety

Under the projected plans, the ramp to the down platform is to stay. The ramp to the up platform is to be removed, and additional access will be provided by a lift. This is the smallest lift allowed under the DDA – 1500mm by 1100mm. At present, the exit from this will be via a lobby with the exit door at the almost directly at the top of the stairs. At most this is a metre from the top of the stairs.

With the ramp gone, there will be people trying to get up the stairs, some running to catch a train that is arriving, others trying to leave the platform, with the following users cutting across the flow in both directions – cyclists, wheelchair users, people with heavy luggage, people with children in pushchairs and elderly people who have used the lift to save their legs. All this will be happening just at the top of the stairs.

Even if a new position were to be found for the lift, there will still be cross flow, as people with wheelchairs, luggage and cycles push across the platform. For such a busy station, the platforms are relatively narrow, and any disturbance puts people in danger. Network Rail say they are going to widen the platforms, but the only way that this could be done would be to move the rails into the centre of the track, where at present there are no lines. There were once two through lines, which were removed many years ago. It would be acceptable to widen the down platform, using the space then created. Indeed, this would be an improvement, as the curve on the line through the station means there is quite a gap, and a high step up at the far end. However, on the up platform the opposite would apply, with the curve being made tighter and increasing the gap, in contravention of present safety guidelines.

There is the issue of emergency exits. Under the present plans, the emergency exit for the up platform is through the commercial Unit 5. It is unclear what will happen if Unit 5 is closed. It is not even clear whether or not there are railings between the platform and the terrace of Unit 5 – plans suggest that there are. The lift in Unit 5 is smaller than that allowed under the DDA – that is an issue I also raise in Section 4 – the Disability Discrimination Act. To make matters worse, the emergency exit from Unit 5 is through the station. Thus, under the present plans, if there were an emergency which affected both the station and Unit 5, the only emergency exit would be for passengers to get on to the line. With a viaduct high above the river at each end of the station, this must be unacceptable.

The ramp is particularly important for emergency vehicles. The lifts as designed, whether in Unit 5 or the station, will not allow use of a stretcher in them. If anyone were to have suffered a head injury, for example, which meant they had to be strapped to a stretcher and taken off with the minimum of movement, they would, again, have to be taken across the line. Is this legal?

There is no doubt that the presence of the ramp provides a much-needed escape from pressure on this platform. On safety grounds alone, its removal is a badly flawed decision. No one is suggesting that there should not be a lift, provided it is put in a sensible position which does not interfere with passenger safety, but in the interests of safety alone, given the position of the station, the ramp MUST be retained.

There are further issues with safety in the plans, caused by removal of the one way system around the back of the station. There is a well-used footpath which runs form Widcombe, on the other side of the river, across a footbridge, under the line and leads into the city centre. Previously, apart from cars coming down from the ramp on the down platform, pedestrians only had to watch out for cars coming from the west end of the station. With the ramp removed and a so-called plaza created, this system will cease, and all traffic, including taxis will now have to come down through one tunnel, do a U-turn, and go back either up a taxi tunnel or back the way they came. This means that pedestrians will now be faced with cars doing U-turns in their path. It may be that the intention is to direct pedestrians to go round the station to avoid this, but they will not do that as it will make their journey longer. What’s more, the scheme only allows for eight taxis before a traffic jam will be created, causing further confusion on the route of the footpath.

3. Passenger Comfort and Satisfaction

Removal of the ramp is going to cause loss of amenity for many users. Although this is being done in the name of the disabled, many disabled do not want the ramp removed, but their voices are being ignored. (See also Section 4.) I have spoken to many users of the station, and no one can see the point of removing the ramp. Most feel that the station be less passenger-friendly if it is removed.

The ramp means that, as already stated, disabled of many types, not necessarily in a wheelchair, can be driven up to the platform. This is an advantage also enjoyed by the elderly and those with a large amount of luggage. Even if a larger, better-sited lift were to be provided, this would still be less convenient for these people. A well-sited lift would enhance the station, but removal of the ramp, even with such a lift, would make passengers’ experience less convenient.

This particularly applies when we look at cyclists. In an age when cycling should be encouraged, the proposals discourage its use. At present, many cyclists ride to the station, lock up their bikes under cover at cycle racks on the platform, which are therefore very secure. It is true that on their return, they have to cross to the other platform, but they do this in the knowledge that their bike will be there. Under the new plans, less racks are to be provided, they will not be on the platform but on the station concourse, they will not be under cover, and, above all, they will not be secure. The only security that the operators are prepared to offer is that of CCTV – and B&NES is cutting down on its CCTV operators. Women cyclists in particular feel disadvantaged by this move, as they feel it is opening them to risks of having to find their way home by public transport at night if the bicycle is stolen, or even being attacked as they unlock the bike from a rack from one of the exposed positions in which the racks will be placed. While the use of racks on the platform may not be idea, an intelligent use of the ramp would be to provide disabled parking under cover at the top, and secure cycle sheds also at the top under cover.

Then there are cyclists who use the train. At present they ride up the ramp, out of the way of most pedestrians, and can put their bike straight on the train. Under the future plans, they will either have to use the lift, to the inconvenience of themselves and other lift users or take the bicycles up the stairs. To get in the lift, the bike will have to be tipped on end. Neither of these options is good news for cyclists or other users of the station.

Outside the station, the taxi rank will be confined to the tunnel. At present, passengers come out of the station and queue for taxis under the cover of the station canopy – particularly important in bad weather. In future, they will have to walk out of the station to the tunnel. It is not clear where they are expected to queue but even walking to the taxis is going to take them from being under cover. There will be a drop-off point outside, but at present there is short term parking in case the train is late. This will go and anyone waiting will be expected to use the car park in SouthGate – on the other side of the road and at considerable expense.

Finally, it is far from clear that investigations have been made to see if the ramp is structural. If it is holding up the area at the top – and given Brunel’s use of tamped down earth for urgent structural repairs, and given that the archaeologists found this at the top, this may well be the case – then the ramp’s removal could start a landslide which will at the very least close Dorchester Street, and could result in the closure of the station. This is a worst case scenario, but I have spoken to people who are aware of Brunel’s building methods, and they feel that this is a possibility which should not be ignored. The chances of finding an ashlar facing, which the developers keep insisting will be revealed, are negligible. The very best one can hope for is a rubble stone facing, but if there is no facing at all, then a collapse is possible.

4. Disability Discrimination Act

Much of what is being carried out is being done in the name of the disabled. However, even Network Rail seems to be unaware of the DDA. Starting with the plaza, first of all there are steps – unsuitable for the visually handicapped and those in wheelchairs. The chairman of Network Rail told the local MP Don Foster that there would be a wheelchair route across the plaza – he is apparently unaware of the guidelines for station concourse which state that a wheelchair route has to interconnect (my italics) all the facilities – this does not. A person in a wheelchair has to take a convoluted route to access all of the facilities. What is more, both the visually handicapped and the wheelchair-bound coming from the bus station have to take a very long route round to access the plaza – much further than the able-bodied.

Network Rail also says that the ramp is too steep to be acceptable for wheelchair access. This is untrue. Assuming the architects’ drawings are correct, the gradient is less than the 1 in 20 limit. What the ramp lacks are resting places. However, there are three points to be made here. First of all, the ramp is in the curtilage of a Grade 2* listed building, so normal rules can be more relaxed. Secondly, people in powered wheelchairs have told me they have no difficulty going up it, and one person has told me she has been pushed up it. Thirdly, if the parking were removed from it, which would be an asset as it makes it dangerous for pedestrians and cyclists, then it must be possible to build resting places. Another option is to use it in conjunction with a lift for those who do not feel able to tackle the ramp. Simply taking it away is short-sighted, and definitely not what disabled people want to happen.

Disabled parking is at present at the top of the ramp and is under cover. The proposed parking will be at the back of the station and, as some disabled have pointed out, creates an inconvenient hike to the proposed lift for the up platform. The Parkinson’s Disease Group in Bath is very unhappy at the thought of its members having to use a lift rather than being driven up to the platform. The proposed spaces are at best only partially under cover, and of the four places, one is not covered at all. As it is not clear what parking will be at the top of the ramp to the down platform, it is not possible to say whether or not the overall number of disabled parking spaces will be reduced.

As the railway station is being linked with the bus station as a combined “transport hub”, the facilities at the bus station should also be considered. The parking at Bath Spa Station is also presumably for the bus station. This is at present without any disabled parking or even a pull-in and therefore the whole bus station is presumably in breach of the DDA.

The emergency exit for the up platform is said to be through Unit 5. As already noted, it is far from clear how easy the access from the platform to Unit 5 is going to be. But the lift in Unit 5 is smaller than the minimum required by the DDA.

5. My Solution

1. The whole ramp area should be returned to Network Rail – it should never have been taken from them as it is manifestly an essential part of the station. Given that the safety concerns raised by Network Rail when the CPOs were issued have never been resolved, despite promises that they would, it may be possible to show that the handover of property was improperly obtained, as NR only decided to remove its objection to the CPO because these promises were made but subsequently have not been kept.

2. Keep the ramp, but clear it of general parking.

3. At the top, have covered parking for the disabled, mothers with pushchairs and secure cycle sheds. There could also be a ticket machine of the type installed at unmanned stations.

4. Have designated parking for emergency vehicles.

5. Put in a pedestrian route down the ramp, which would be covered. This could also be used by those in powered wheelchairs.
6. For those who need a lift, put a lift at the end of what was the goods line. This would then open out directly at street level. This would be convenient for the disabled coming from the bus station. I appreciate that this might mean loss of historical material, but far less than is at present proposed. This would be supplied with power from the bus station. It could be a big lift and would provide a safe exit for the disabled in the event of an emergency at the station.
7. Put in a one-way system so that even those parked on the ramp have to turn right to go round the back of the station, so that pedestrians can cross safely from the station to the bus station.
8. Allow the taxi rank to remain where it is, but again, the taxis must go round the back of the station. Short term parking could also then remain at the front, but would still use the one-way system.
9. Finally, landscape the ramp.