Proposed Main Modifications

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cycle parking standards within the Local Plan, rather than just referring to the existing (or any new) SPD to allow for out-of-date standards to be reviewed when necessary.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 However it fails to take into account that both the Welwyn and Stevenage SPDs are out-of-date (2004 and 2012 respectively) and that a new census will be carried out in 2021.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 NHDC have based their comparisons on the existing data, which is out-of-date.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.

Support proposed additional criterion requiring sustainable modes of transport to be provided having regard to the Stevenage Mobility Strategy.
Support proposed reference to a requirement for GP provision.

Support specific references to increasing active and sustainable travel and the need for sites adjacent to Stevenage to make appropriate provision. This is in line with the Stevenage Mobility Strategy and the Stevenage Local Plan, as well as LTP4 objectives.
Support specific reference to consultation with Stevenage Borough Council.
Support proposed addition of clarification of need in relation to GP provision.

Support specific references to increasing active and sustainable travel and the need for sites adjacent to Stevenage to make appropriate provision. This is in line with the Stevenage Mobility Strategy and the Stevenage Local Plan, as well as LTP4 objectives.
Support specific reference to consultation with Stevenage Borough Council.
Support proposed addition of clarification of need in relation to GP provision.

Support specific references to increasing active and sustainable travel and the need for sites adjacent to Stevenage to make appropriate provision. This is in line with the Stevenage Mobility Strategy and the Stevenage Local Plan, as well as LTP4 objectives.
Support specific reference to consultation with Stevenage Borough Council.
Support proposed addition of clarification of need in relation to GP provision.

Support proposed amendments to 3rd bullet point relating to flood risk and consultation being required with both HCC and SBC.
Support proposed additional bullet relating to transport assessment and improving accessibility for non-motorised highway users.

Support proposed detail around flood risk on Stevenage Road to support additional text proposed within the Policy.

Please refer to our comments on T2. We retain our objection to the inclusion of out-of-date parking standards within the NHLP and would recommend that a modification was proposed to remove these and instead rely on the SPD, which can more easily be updated in order to reflect up-to-date policy thinking, in particular the key push towards sustainable travel.