Cycling lawyer Ralph Smyth has written Southwark Cyclists response to the Council’s proposed new plan. The Travel section needs a rethink in the light of national transport planning guidance  published in October last year, he says.

“This requires the preparation of a substantial evidence base and a thorough rethink of this section will be required. In particular:

• Critical locations on the road network with poor safety records should be identified.

• The plan needs testing with different transport scenarios, e.g. different cycling growth rates.

• Consideration of capacity: this is very relevant for cycling as flows will need to double many times over if we are to reach continental norms, particularly given a growing population.

• The scope and options for maximising travel planning and behavioural change.

While there are development management policies (what should be given planning permission), in relation to plan-making (the vision for the pattern of development) there is much less detail. The Plan is inadequate in that it fails to identify opportunities to shift to more sustainable travel or specific things that could be funded through contributions from developers.” More specifics required. 

Without more thinking ahead, there is a real danger that the plan will be rejected by government

“Although the Plan refers to the Southwark Cycling Strategy (‘the Cycling Strategy’) and London wide initiatives such as superhighways, it is important to highlight the different timeframes involved: the Plan is not due to enter force until 2018, by which stage superhighways should be complete, at least in inner London and the Cycling Strategy will be over halfway through its currency. Unfortunately, while TfL is thinking ahead to the late 2030s for public transport, such as the Bakerloo extension, when it comes to cycling Southwark’s planning stops after 2018.

There is a real likelihood of the Plan being declared unsound. In January 2015, the Secretary of State for Communities & Local Government, not known previously for his pro-cycling stance, rejected an urban extension of Aylesbury because of a lack of high quality cycle routes: this meant that the development could not be described as sustainable. In February 2015, a planning inspector rejected the Durham Local Plan, ordering the local authority to plan for much greater use of public transport and cycling. The local authority said it was ‘beyond disappointed’, as it would have to start the whole planning process – many years of work – from scratch.

There is a clear warning for Southwark here of failing to be sufficiently ambitious, not in relation to 2015 but for 2018 when the decision on soundness will be made. With the Infrastructure Act 2015 setting out a ground-breaking requirement for a national long-term Cycling & Walking Investment Strategy, the planning system can be expected to require even greater change.” No one wants so much wasted effort.

Strategic policy: sustainable transport

Policy SP4 is flawed in two respects:

• it assumes that reducing the need to travel will reduce congestion: but London is so congested that if you free up road space, other traffic will fill it;

• it focuses on providing sustainable travel choices, which there are already many, rather than improving their quality (e.g. lack of bus priority, permeability for cycling).

The policy should be rewritten with two replacement policies. 

• increasing the advantages of sustainable travel modes relative to driving;

• motor traffic reduction: given that motor traffic should be restricted through residential areas and centres, while more space for walking and cycling is needed on major routes.

The Plan should set out clear motor traffic reduction targets, increasingly ambitious over time.

Locating developments

DM13 is not clearly written and in places does not make complete sense, e.g. “DM 13.2 Development must be located to provide sustainable transport options rather than motorised trips to”: most if not all public transport trips are motorised, while the location of a development in itself will not create quality conditions for cycling and walking. There is a misunderstanding of the spatial patterns of development that maximise active travel.

Rather than simply focusing development at larger hubs, what might be called the Surrey Quays model of development, dense mixed-use development should be encouraged in the majority of the borough that is already highly accessible by sustainable modes. This alternative, which the Germans call ‘short trip towns’, stimulates trip chaining, in other words lots of linked short trips that are best walked or cycled.

The reasons section assumes that cycling is about going between developments and public transport. In fact only a small proportion of cycling trips are to public transport nodes. The problem here is that Public Transport Accessibility Levels (PTAL) form the basis of accessibility judgements. This is calculated by assessing frequency of public transport and walking distance to it: in other words it ignores cycling. Until there is a London-wide replacement of PTAL that assists in planning for a high modal share of cycling, Southwark should increase PTAL levels in locations well served by high quality cycling routes. This is also relevant for parking standards.

Transport Impacts

DM14 should be rewritten in particular to require individual developments to reduce net private motor traffic or at least ensure no net increase through a trip credit approach. Any such traffic that cannot be minimised from a new development should be offset by making payments to reduce existing private motor traffic. This could help fund the retrofitting of high quality cycle parking in estates and older offices, as well as extending the reach of travel planning activities run by local bodies such as Business Improvement Districts, for example.

In light of the successes of the Quiet Deliveries Demonstration Scheme, explicit support for night time deliveries, with suitable conditions to minimise noise, should be considered. There should be a presumption against deliveries, even if off-street, during peak hours. Where a freight consolidation centre is in operation, businesses should be required to make reasonable use of it.

A critical omission is the absence of any policy regarding the impact of construction on cycling and walking – whether routes being closed off (e.g. Upper Ground) or the danger of construction traffic. New policy is required to:

• require all construction traffic for developments in Southwark to meet current best practice, currently set by Crossrail;

• not to hinder access (whether road closures or ‘cyclist dismount’ signs) to cycling routes, unless exceptional circumstances (e.g. it would prevent delivery of major regeneration).

Walking and cycling

The proposed DM15 is flawed as it focuses on routes and facilities, without linking to the overall quality of the public realm. The PPG states that “[t]he likelihood of people choosing to walk somewhere is influenced not only by distance but also by the quality of the walking experience.” The principle applies to cycling, as for either mode, people are not enclosed in metal boxes, so are strongly influenced by the public realm.

The transport user hierarchy was controversially removed from the London Plan by the current Mayor. It is now part of national guidance so should be referenced in this plan. It states:

“The transport user hierarchy should be applied within all aspects of street design – consider the needs of the most vulnerable users first: pedestrians, then cyclists, then public transport users, specialist vehicles like ambulances and finally other motor vehicles.”

So the Plan should require designing in walking and cycling from the start, in order that these modes become the default option for shorter journeys. This in turn requires:

• high quality public realm, in line with the TfL Road User Taskforce recommendations for a street family;

• Home zones, which are highlighted in the NPPF, should be explicitly mentioned;

• designing out speeds of above 20 mph or above 12 mph on shared surfaces;

• filtered permeability: maximising permeability for those on foot and cycle;

• providing sufficient space for significantly higher walking and cycling levels in future.

DM16 Infrastructure

A critical omission is the lack of any proposals for freight consolidation centres, which can reduce HGV and van traffic as well as stimulating use of freight cycles for the last leg of a delivery.

There should be the following changes/additions:

• Add in removal of gyratories, in particular St George’s Circus as well as Surrey Quays and Tooley Street;

• Change public transport to sustainable travel and provide a map showing schemes;

• Add in TfL street family approach from Road User Taskforce – converting/upgrading Southwark’s streets will take many years and lots of funding.

• There is a real lack of east-west and non-radial cycle routes for much of the borough in the Cycling Strategy: also add in Peckham Vision proposals for new cycle routes;

• Explicit commitment to adding green infrastructure along key walking and cycling routes;

• Amend bus priority to bus and cycle priority, add specific locations including around London Bridge station (huge increase in walking due as well as new superhighway in already congested environment).

• Redefine the new river crossing so that it is only for walking & cycling.

• Be specific about the ambition to extend the cycle hire scheme, so as to be able to secure developer contributions: it is suggested that the Overground would be a sensible boundary.

• Keep Cross River Tram in.

Car parking

The requirement in DM17 to provide car parking that is free for the first hour is objected to. This will discourage sustainable travel and is wholly unnecessary in a borough where car ownership is already a minority activity: it effectively means businesses and indeed customers who are not driving, to subsidise those using cars.

Parking for the mobility impaired

DM18 should be expanded to consider cycle parking facilities for the mobility impaired, including adapted cycles and tricycles.

Car clubs and cycle hire

In DM19, references to car clubs should be changed to shared cars in line with guidance from national charity CarPlus. Cycle parking should be provided at shared car parking bays. The requirement for cycle hire fobs is strongly welcomed but should be expanded to proposed docking stations. In areas outside the TfL cycle hire scheme, alternative ways to offer cycles to residents should be considered.

Parking Standards (contained in annex)

In relation to commercial property, the draft does not propose to change existing maximum parking levels for motor vehicles, which are in line with the latest version of the London Plan.

The proposal to limit residential car parking more than Londonwide standards is supported as:

• Current standards are leading to grossly excessive parking, e.g. tower block next to Blackfriars with 200 spaces consented in 2014;

• Replacement of owned vehicles by shared cars are likely to increase in future, requiring far fewer spaces;

• Maximising greenspace, social housing and space efficient forms of travel is critical to delivering sustainable growth – excessive parking hinders all three;

• DfT research into parking standards show it is one of the most effective means to influence travel choices;

• Current policy is based on the views of a planning minister who is strongly pro-parking, yet he is unlikely to be in post for the Examination in Public of the Plan.

In addition or at least in the alternative, the use of PTAL, which is based on walking distances to public transport, should be supplemented by consideration of cycle accessibility. This would mean that developments near a high quality cycle route could be considered in a higher PTAL category.

The proposed increase in cycle parking is strongly supported, however evidence suggests that it may still be insufficient:

• there are examples of offices built in the last five years in the City, where there is a waiting list for staff cycle parking;

• similarly there are recently constructed residential developments in Hackney where there is already insufficient cycle parking.

With cycling levels starting from a very low base in Southwark, there is a substantial likelihood that the proposed minimum levels will not be adequate for the lifetime of developments proposed. While not all residents will cycle, some residents are likely to have more than one cycle, if not specialist cycles that require more space, such as trailers and large cycles for carrying children. There is nothing in the proposed standards to cater for this.

A Local Development Order should be proposed that would allow people to install cycle parking sheds in their front gardens, where there are no reasonable alternatives, without the hassle and cost of seeking planning permission.

Design

PPG requires consideration of adaptability (e.g. of much higher cycle flows in future) but it is not mentioned here. The PPG also now includes the user hierarchy (consider those on foot first, then cycling etc.), which was controversially removed from the London Plan. This should be explicitly included.

NB in relation to 39.1.8 the DDA no longer exists, as it was repealed and replaced by the Equality Act 2010.

Designing out crime

As set out above, this should include designing out road traffic crime, such as speeding and inconsiderate driving, so DM41 should be amended accordingly.

Urban Greening & Green Infrastructure

Policy DM60 should be linked with policy on travel and public realm. For example removing car parking spaces can allow more trees and ‘pocket parks’ to be planted. There should be a policy to green key walking and cycling routes to make them more like greenways or linear parks.

The policy also now requires reduction in street clutter and the user hierarchy (consider those on foot first, then cycling etc.), which was controversially removed from the London Plan.

Air Quality

Policy DM68 is potentially unlawful – it needs to make sure that development does not prevent air pollution being reduced where there is an exceedance, not simply prevent increases. This is how policy in the National Networks National Policy Statement, designated in January 2015, has been set out. Binding measures are needed to back up modal share targets.

Noise

In order to comply with the NPPF, additional policy in DM69 is needed to identify and protect areas of tranquillity, such as in and around parks. Although there is nowhere in Southwark that is very tranquil, there are relative areas of tranquillity. There are potential strong synergies with introducing green infrastructure and restricting motor traffic, which is one of the major sources of noise. Paris, for example, has had a successful policy of introducing ‘green quarters’. Introducing such areas next to parks as buffers could improve connectivity for people and wildlife to Southwark’s green spaces, as well as improving tranquillity in the core of such areas.

Let’s hope that Southwark Council heed these wise words — and that if they don’t the government makes them.