MM120 - Page 90 Policy T2

Showing comments and forms 1 to 3 of 3

Object

Proposed Main Modifications

Representation ID: 6845

Received: 28/01/2019

Respondent: Rumball Sedgwick

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

See attached. Not positively prepared.

Full text:

See attached

Attachments:

Support

Proposed Main Modifications

Representation ID: 7076

Received: 11/03/2019

Respondent: Pirton Parish Council

Representation Summary:

See attached

Full text:

See Attached

Attachments:

Object

Proposed Main Modifications

Representation ID: 7266

Received: 10/04/2019

Respondent: Stevenage Borough Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Note from Inspector does not alleviate our concerns on residential and cycle parking.
Publishing the standards in the Local Plan do not allow for future updates of the data.

Full text:

We object to the Modifications proposed to Policy T2. The note provided to the Inspector on parking (ED153) does not alleviate our concerns with regards to the approach taken by NHDC to set out residential and cycle parking standards within the Local Plan, rather than just referring to the existing (or any new) SPD to allow for out-of-date standards to be reviewed when necessary.
The NPPF requires that parking standards take into account local car ownership levels. The standards set out in the emerging NHLP are based on 2001 census data. Note ED153 seeks to justify this by comparing with 2011 data and benchmarking against neighbouring local authority parking standards. However it fails to take into account that both the Welwyn and Stevenage SPDs are out-of-date (2004 and 2012 respectively) and that a new census will be carried out in 2021. Publishing the standards within the Local Plan as opposed to an SPD does not allow for future updates of this data to be taken into account.
In Stevenage, for example, the Parking Provision SPD is due to be updated and cycle parking standards, in particular, will be amended significantly to reflect the revised LTP4 and aspirations of the Stevenage Mobility Strategy to prioritise walking and cycling. NHDC have based their comparisons on the existing data, which is out-of-date. For cycle parking in particular, the standards set by NHDC are not aspirational in terms of encouraging sustainable travel, which is a key requirement of the NPPF.
To make this policy sound, we would recommend further modifications are made to remove the standards from Appendix 4 and to instead refer to the SPD, which should be updated in due course to reflect LTP4.