This is the text of our response to the Twickenham Riverside planning application. Please take a moment to pop down the sherry and add your opposition! You can make your comment on the planning website.
We oppose the application on grounds of its failure to comply with LBRUT, Greater London Authority and Government policies:
Twickenham Area Action Plan 2013 (‘TAAP’) sets out LBRUT’s policy framework for the site. TAAP includes a principle to improve the pedestrian environment and reduce dominance of parked and moving traffic (220.127.116.11). TAAP states that the whole area should be changed in a comprehensive way, and that each phase must take account of the overall future layout (18.104.22.168). TAAP aims to improve the environment of the Embankment including reduction in car parking (22.214.171.124).
LBRUT’s Core Strategy 2009 includes spatial policy CP9 which aims to revitalise Twickenham Town Centre, creating a high-quality district centre serving residents, workers and visitors, founded on the principles of sustainability. Transport considerations include improving pedestrian and cycle links to and from the centre, and improving traffic management to manage flows and reduce dominance of vehicles on the town centre environment.
The Core Strategy is in the process of being revised and incorporated into LBRUT’s Local Plan. The Local Plan states (LP 44 B) that the council will ‘ensure that new development is designed to maximise permeability within and to the immediate vicinity of the development site through the provision of safe and convenient walking and cycling routes, and to provide opportunities for walking and cycling, including through the provision of links and enhancements to existing networks.’
The London Plan 2016, published by the Mayor’s Office, states that London should be ‘a city where it is easy, safe and convenient for everyone to access jobs, opportunities and facilities with an efficient and effective transport system which actively encourages more walking and cycling and makes better use of the Thames’. The Plan encourages patterns of development that (1) reduce the need to travel especially by car, (2) improve the capacity and accessibility of sustainable travel modes such as public transport, walking and cycling, and (3) encourage shifts to more sustainable forms of transport.
Healthy Streets For London 2017 (‘HSL’) published by the Mayor’s Office, a core element in the Mayor’s overall plan for London, states ‘Walking and cycling are the healthiest and most sustainable ways to travel, either for whole trips or as part of longer journeys on public transport… This will only happen if we reduce the volume and dominance of motor traffic and improve the experience of being on our streets.’
The National Planning Policy Framework 2012, (‘NPPF’) seeks to ensure that the transport system is balanced in favour of sustainable transport modes. Developments should be located and designed to give priority to pedestrian and cycle movements, and should create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians.
Failings in regard to TAAP
The application is not a comprehensive plan as required by TAAP. The site borders Water Lane and the Embankment, yet the plans do not consider any of the improvements of these thoroughfares anticipated by TAAP, for example reduced car parking along the water-front. The application’s car parking will increase traffic on the Embankment in contravention of TAAP.
Failings in regard to the Core Strategy and the Local Plan
The application encourages cars by excessive provision of car parking. Increased parking will increase the dominance of cars in the town centre environment in contravention of the Core Strategy. The application offers no improvement to cycling between the riverside and King Street, a requirement of the Core Strategy. The application fails the requirements of the Local Plan in not considering the riverside cycle route to Richmond or between the riverside and King Street which would have provided permeability to the site.
Failings in regard to the London Plan and HSL
The provision of cycle spaces at the rear of the basement does not encourage cycling as required by the London Plan as there is no improvement of cycling infrastructure in the immediate area; notably no northbound cycling on Water Lane to link with King Street. The application does nothing to reduce car travel, a requirement of the London Plan and HSL. The application does not improve the on-street experience or create a space where walkers and cyclists are free from manoeuvring cars.
Failings in regard to NPPF
The application gives no priority to cycle movements as required by NPPF. The car parking spaces within the development and the access via the Embankment will lead to increased conflict between pedestrians and cyclists on the one hand and traffic on the other, in contravention of NPPF.