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Our representation to the Council’s consultation on local plan

June 12, 2013

On behalf of the Wandsworth Branch of Living Streets we wish to make the following comments on the proposed submission of Local Plan Documents for the Borough of Wandsworth. It is understood that the rationale for the review is to ensure that Local Plans accord with the policies and guidance given in the :

  • National Planning Policy Framework (NPPF, 2012), and
  • London Plan (Greater London Assembly, 2012)

Our concern is that revisions to the Local Plans do not pay sufficient attention to the above documents with regard to the promotion of sustainable forms of urban transport, in particular walking and cycling. Although the documents that comprise the Local Plan do mention sustainable transport we find that there is scant action towards this objective and that the policy guidance specified below have largely been ignored.

Paragraph 35 of the National Planning Policy Framework.

“ Plans should protect and exploit opportunities for the use of sustainable transport modes for the movement of goods or people. Therefore developments should be located and designed where practical to :-

  • give priority to pedestrian and cycle movement and have access to high quality public transport facilities,
  • create safe and secure layouts which minimise conflicts between traffic and cyclist or pedestrians, avoiding street clutter and where appropriate establishing homes zones”,

Policy 6.1 (Strategic Approach) of the London Plan seeks to encourage closer integration of transport and development by :-

  • seeking to improve the capacity and accessibility of public transport, walking and cycling, particularly in areas of greatest demand,
  • supporting measures that encourage shifts to more sustainable modes and appropriate demand management,
  • promoting greater use of low carbon technology so that carbon dioxide and other contributors to global warming are reduced, and
  • promoting walking by ensuring an improved urban realm

Although walking and cycling are briefly mentioned in the Local Plan documents there are no specific measures to comply with policy directives 6.9 and 6.10 of the London Plan, namely :-

(Policy 6.9, Cycling, Para 6.33) “The Mayor is committed to seeing a revolution in cycling in London. The quality and safety of London’s street environment should be improved to make the experience of cycling more pleasant and an increasingly viable alternative to the private car. By providing safe and attractive routes that are easy to navigate people may be encouraged to cycle more, which will have health benefits for them and also help tackle climate change”.

(Policy 6.10, Walking). “The Mayor will work with all relevant partners to bring about a significant increase in walking in London, by emphasizing the quality of the pedestrian and street environment, including the use of shared space principles – promoting simplified streetscape, decluttering and access for all”.

Moreover, the Local Plans have not addressed the strategic objective stated in the London Plan that the “Mayor will, and boroughs should, take an approach to the management of streetspace that takes account of the different roles of roads for neighbourhoods and road users in ways that support the policies in this Plan promoting public transport and other sustainable means of transport (including policies 6.2, 6.7, 6.9 and 6.10) and a high quality public realm. Where appropriate, a corridor-based approach should be taken to ensure the needs of street users and improvements to the public realm are co-ordinated”.

The significant of sustainable transport has been recognised for some time and efforts to achieve this are specified in numerous policy guidelines, for instance :-

  • Local Measures to Promote Walking and Cycling as forms of Travel or Recreation (National Institute for Health and Clinical Excellence : Public Health Guidance 41, 2012)
  • Manual for Streets (Volume 1, Department of Transport, 2007), and
  • Planning Policy Guidance 13 (Department for Communities and Local Government, 2006)

Escalating use of the private motor vehicle within the Borough, and throughout London, cannot continue indefinitely and has already created unacceptable health conditions for residents. Road transport is responsible for up to 70% of air pollution in urban areas where most human exposure to air pollution occurs . Despite improvements to exhaust emissions, exposure to air pollution is a significant cause of mortality in England. The House of Commons environmental audit report on air quality noted that, “poor air quality reduces the life-expectancy of everyone in the UK by an average of 7 to 8 months and up to 50,000 people a year may die prematurely because of it”.

The situation in London is more acute. Clean Air in London’s (CAL’s) analysis of the latest data from the European Environment Agency (EEA) confirms that London again had the highest levels of nitrogen dioxide (NO2), a toxic gas, of any capital city in Europe in 2011. London also plummeted 346 places in the rankings for dangerous airborne particles (PM10).

It was hoped that the Local Plans would do more to promote alternative means of urban transport other than the private motor vehicle. Bicycles are used for only 2% of journeys in Britain, compared to about 26% in the Netherlands, 19% in Denmark and 5% in France . Yet of all trips made in Great Britain in 2009, 20% covered less than 1 mile and more than half (56%) of car journeys covered less than 5 miles (Department for Transport 2010a).

Finally we draw your attention to the guidance given in the Planning Policy Guidance Note 13, which states that, “In taking decisions on the management of traffic, authorities should ensure that they address the needs of all users. Within town centres and other areas with a mixture of land uses, priority should be given to people over traffic. Well designed pedestrianisation and pedestrian priority schemes generally prove popular and commercially successful, and local authorities should actively consider traffic calming and the reallocation of road space to promote safe walking and cycling and to give priority to public transport”.

This guidance has important implications for the environment and commercial well being of the borough’s town centres, all of which are prejudiced by unacceptably high volumes of traffic to the detriment of other road users, namely pedestrians and cyclists.

You can download our full letter with annex (which contains relevant extracts from the above documents) HERE.

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