139 Hllingdean Terrace Brightn BN1 7HF Tel: 01273 553044 Mr James Appletn: case fficer AWDM/0961/17 Adur and Wrthing District Cuncils Develpment Management Prtland Huse 44 Richmnd Rad Wrthing, West Sussex BN11 1HS 4 July 2018 Dear Mr Appletn, AWDM/0961/17 Land East Of Shadwells Rad At Mash Barn Estate Mash Barn Lane Lancing West Sussex (the New Mnks Farm site) This letter includes the attached / enclsed Nn-Mtrised Users Design Review which frms the evidence base f ur bjectin. ActivePlanning and City Infinity hereby represent ur client Brightn and Hve Friends f the Earth wh have cmmissined us in the matter f the abve planning applicatin, n behalf f the fllwing cnsrtium f rganisatins and representatives: Bricycles; Cycling UK lcal representatives; The British Hrse Sciety; Shreham-By-Cycle; Sustrans Wrthing C-rdinatr; West Sussex Cycle Frum; and Wrthing Cycle Frum. All these rganisatins and representatives supprt this bjectin and the pints made in the critical design review. This letter des nt cmment n the principle f develpment, but n the extent t which the current prpsals have regard t plicies in the Develpment Plan (in this case the adpted Adur Lcal Plan, in particular plicies 1, 5 and 28) with regard t sustainable transprt. It is accmpanied by a critical design review f the prpsals which frms part f ur bjectin. Our design review includes the cnclusin (in paragraph 12.8) that: The applicatin prpsals simply fail t place active travel and NMU prvisin at the heart f the design prcess. The develpment has been largely designed arund the needs f mtr traffic capacity and flw, and s mtring is enabled by the design chices and NMUs are merely prblems t be designed-ut This situatin is, as we demnstrate in this letter, cntrary t the adpted Lcal develpment Plan plicies (particularly, plicies 1, 5 and 28) and als the Natinal Planning Plicy Framewrk 2012 and draft 2018 with regard t the presumptin in favur f sustainable develpment and the requirement f lcal authrities t make plicies and decisins that actively manage patterns f grwth t make the fullest pssible use f public transprt, walking and cycling and give pririty t pedestrian and cycle mvements creat[ing] safe and secure layuts that minimise cnflicts between traffic [sic] and cyclists r pedestrians. 1 f 10
We believe that the failings in respect f prperly accmmdating nn-mtrised users are significant and, in sme cases, critical (with regard t safety, cmfrt and fld risk) thrughut the scheme and this means there are bth develpment plan and material grunds fr a refusal t grant planning permissin. Our aim is t achieve a situatin in which the prpsed new hmes, cmmunity hub, schl and emplyment use at Mnks Farm are an pprtunity taken t plan and design develpments that prmte less car-dependent, healthier and mre sustainable lifestyles. Reducing car dependency can als reduce pressure n the rad netwrk, helping t address pr air quality and cngestin. By investing prperly in best-practice infrastructure fr active travel it will be pssible fr develpers and planning authrities tgether t make steps twards reducing the diseases f inactive lifestyles besity and verweight, which affects tw thirds f the adult ppulatin, heart disease and type-2 diabetes. The alternative is that priritising car-riented develpment and failing t prperly prvide fr active travel will feed the cntinued rise f diseases related t inactivity, which are a significant and increasing financial burden upn the Natinal Health Service and results in individuals spending mre f their life years in preventable ill health. Gd example guidance n develping healthy cmmunities can be fund here: https://www.glucestershireccg.nhs.uk/wp-cntent/uplads/2012/12/active-planning-tlkit-2.pdf with further guidance here: http://www.rtpi.rg.uk/media/1119674/rtpi_prmting_healthy_cities.pdf (bth 2014) The purpse f this letter is t: 1. State that the presumptin in favur f sustainable develpment cannt be applied with reference t active travel as this matter is nt adequately addressed by the prpsal in a way that wuld encurage and priritise pedestrian, cycle and equestrian travel and is therefre cntrary t Plicies 1, 5 and 28 f the adpted Adur Lcal Plan 2017, Natinal Planning Plicy Framewrk (2012) and Draft Natinal Planning Plicy Framewrk (2018). We believe that permitting this develpment as presented wuld set an undesirable precedent that wuld make unsustainable car-dependent develpments that fail t prperly accunt fr the need t incrprate and priritise active travel harder t resist, even in the presence f increasingly health-riented planning plicies. 2. Object t the remval f the existing pedestrian and cycle crssing at the site knwn as Sussex Pad and its replacement with inadequate and diversinary alternatives, cntrary t Lcal Plan plicies 5 and 28. 3. Object, n grunds f severely sub-ptimal quality in relatin t Highways England design guidance set ut in IAN195/16 and by reasn f significant diversin and critical engineering design failures, t the prpsed eastern walking / cycling / equestrian rute and new bridleway t the nrth f the A27 (subject t a separate planning applicatin t SDNP) that is prpsed t replace the existing Sussex Pad signalised crssing f the A27. 4. Object, n grunds f sub-ptimal quality in relatin t the guidance in IAN195/16 and by reasn f significant diversin fr pedestrians in particular t the signalised crssing arrangement at the prpsed rundabut cnnecting the A27 with the site as described in detail in the accmpanying reprt, and the failure t priritise mvement n ft and cycle by making gd quality prvisin fr nn-mtrised cnnectivity thrugh the site and neighburing areas that cmpares well with the quality and extent f infrastructure prvided fr mtrised traffic. 5. Object t the pr quality and inadequacy f many f the shared use paths indicated as suitable fr walking and cycling within the prpsed cuntry park, specifically the substandard widths and surfacing treatments prpsed fr paths and bridges. 6. Object t the lack f infrmatin available abut prpsed cycle parking infrastructure at the prpsed retail develpment (utline applicatin) and within the prpsed husing develpment, and als bject t the size f the garages which will be inadequate fr cstrage f mtr vehicles and cycles. 2 f 10
7. Object t the failure f the prpsals t enable buses t prperly serve the prpsed superstre (IKEA) by prviding a bus stp at the stre entrance. In determining ur respnse, we have taken int accunt cmments frm the West Sussex Cunty Cuncil case fficer and reviewed the West Sussex adptable rads guidance (which is silent n the matter f active-travel). 1 Presumptin in favur f sustainable develpment with reference t sustainable transprt We bject t the failure f the develpment as prpsed t cnfrm with Plicies 1 and 28 f the adpted Adur Lcal Plan in relatin t the presumptin in favur f sustainable develpment and transprt respectively; and the Natinal Planning Plicy Framewrk (2012 and draft 2018) with the presumptin in favur f sustainable develpment in relatin active travel (scial and envirnmental sustainability). If the prpsals are permitted withut imprvement, an undesirable precedent will be set that future similar prpsals d nt need t meet the NPPF definitin f sustainable develpment with respect t incrprating active travel frm the utset f design and masterplanning prcesses. The Natinal Planning Plicy Framewrk (2012 and draft 2018) bth state that plans and decisins shuld apply a presumptin in favur f sustainable develpment, which includes aspects f scial, ecnmic and envirnmental sustainability. The draft NPPF (2018) is an increasingly imprtant material cnsideratin and blsters the current NPPF (2012) requirement that planning plicies and decisins shuld aim t achieve healthy, inclusive and safe places that: Prmte scial interactin, fr example thrugh multiple cnnectins within and between neighburhds; Are safe and accessible, fr example thrugh the use f clear and legible pedestrian rutes ; and Enable and supprt healthy lifestyles, fr example thrugh layuts that encurage walking and cycling The draft NPPF gives further supprt t active travel, illustrating the Gvernment s increasing interest in walking and cycling. It repeats the NPPF (2012) requirement t incrprate active travel mdes in plan-making and develpment prpsals, s that: The ptential impacts f develpment n transprt netwrks can be addressed; and Opprtunities t prmte walking, cycling and public transprt use are identified and pursued. Further supprt is given in the draft NPPF t including active travel mdes, stating that in assessing applicatins fr develpment, it shuld be ensured that Apprpriate pprtunities t prmte sustainable transprt can r have been taken up; and Applicatins fr develpment shuld give pririty first t pedestrian and cycle mvements, bth within the scheme and with neighburing areas The NPPF 2012 states that develpment prpsals shuld actively manage patterns f grwth t make the fullest pssible use f public transprt, walking and cycling and give pririty t pedestrian and cycle mvements creat[ing] safe and secure layuts that minimise cnflicts between traffic [sic] and cyclists r pedestrians. Plicy 1 f the adpted Adur Lcal Plan is in cnfrmity with the Natinal Planning Plicy Framewrk (NPPF) in respect f the presumptin in favur f sustainable develpment. The supprting text states that sustainable develpment is a fundamental principle f the NPPF and that sustainable develpment includes a scial rle, supprting strng, vibrant and vital cmmunities; and an envirnmental rle, cntributing t and enhancing ur natural and built envirnment. 3 f 10
Plicy 5 states that at Mnks Farm, there shuld be prvisin f sustainable transprt infrastructure including imprved cycle, pedestrian and equestrian links t Lancing, Shreham-by-sea and the Suth Dwns Natinal Park. In the supprting text fr Plicy 28, the Lcal Plan expresses cncern abut cngestin, air quality and the current piecemeal and pr quality f infrastructure prvided fr active travel and the failure t give pririty first t pedestrian and cycle mvements, bth within the scheme and with neighburing areas. Plicy 28 seeks t encurage develpers t extend the existing cycle netwrk and secure a netwrk f cycle, pedestrian and bridleway facilities linking urban areas, key sites, pen space, cuntryside and cast as well as imprved access acrss the A27. The plicy is weak with regard t active travel whereas Plicy 5 is strng; nnetheless it is clear that the prpsals fail t cntribute psitively t securing a netwrk f cycle, pedestrian and bridleway rutes, certainly when cmpared with the generus and ver-scaled attentin and subsidy given t prviding access fr mtr-traffic. We believe that, cntrary t the NPPF the prpsed develpment priritises the needs f mtr traffic, nt nly in terms f relative quality but als that it is prpsed t be develped in a way that is at the expense f active travel mdes. This is by reasn f the lss f a ppular and well-used crssing (the Sussex Pad), the pr and severely cmprmised quality f prpsed infrastructure design, the failure t integrate active travel in the new develpment and cuntry park, the creatin f new diversinary rutes that are nt cnducive t r suitable fr cnvenient walking, cycling and equestrian use, and the failure t shw that the prpsed active travel rutes are in any way equivalent r better than prvisin made fr mtrised vehicles. The situatin is cntrary t Lcal Plan plicy 5 which seeks imprved infrastructure fr cyclists, pedestrians and equestrians. We believe the prpsed develpment als priritises mtrised access by failing t place cmmunity uses (the primary schl and the cmmunity hub ) where it can be reached by new ccupants and the existing cmmunity within a 10-minute walking radius f the site. This aspect f sustainable develpment is dealt with belw. Our bjectin wuld be reslved by: The retentin f the Sussex Pad crssing cmbined with an imprved netwrk fr active travel; Prvisin f a higher quality standard f active travel infrastructure as utlined belw, and addressing the design quality we require as set ut in the accmpanying dcument; Prvisin f active-travel infrastructure within the existing cmmunity that will mitigate the impacts f the develpment, build scial interactin and cmmunity and prvide mre permeability fr the active travel mdes; and Relcatin f cmmunity uses where they can be accessed by existing and new residents travelling n ft. 2 Remval f the existing pedestrian crssing We bject t the remval f the Sussex Pad pedestrian / cycle crssing as it is cntrary t the NPPF (2012 and draft 2018) and the Develpment Plan - Lcal Plan plicy 5 which seeks imprved infrastructure fr pedestrians, cyclists and equestrians cnnecting the develpment t the Suth Dwns Natinal Park; and Plicy 28, which calls fr imprved access acrss the A27 fr pedestrians and cyclists and states that, in general, The pedestrian and cycle netwrk culd benefit frm imprvements, as it is indirect... [with a lack f] safe crssing pints, and pr surfacing in sme places. Equestrians and vulnerable users, including thse with mbility difficulties, als need t be taken int accunt. In additin, there is a lack f safe pedestrian and cycle crssing pints n the A27. The Natinal Planning Plicy Framewrk (NPPF 2012 and Draft NPPF 2018) is quite clear that develpments shuld be lcated and designed (where practical) t give pririty t pedestrian and cycle mvements and cnsider the needs f peple with disabilities including thse n ft and cycle (NPPF 2012 para 35). We believe that creating a diversinary rute t a sub-standard design will exclude peple with disabilities in particular and is nt acceptable. Our bjectin wuld be addressed by the fllwing measure: 4 f 10
Replacement f the prpsed diversinary rutes with a signalised r grade-separated crssing f the A27 at the Sussex Pad junctin. The crssing must be cnstructed in accrdance with Highways England s Interim Advice Nte 195/16, taking int accunt the needs f disabled pedestrians and cyclists and als equestrians. The crssing and appraches t it must als be designed t maximise persnal safety, als having regard t any impacts n the visual quality f the SDNP. We believe that this can be achieved at a nearequivalent cst t cnstructing the prpsed rute. With reference t the NPPF 2012 test f practicability we believe that the retentin f sme frm f crssing at this pint is r can be made practicable. This view is strengthened by the prpsed 50mph speed limit, which if prvided between the Lancing Rundabut and the A283 intersectin, brings a signalised crssing int scpe with reference t Highways England design standards. 3 Pr quality f the prpsed walking / cycling alignment via the River Adur We bject t the substandard quality f the prpsed walking and cycling rutes alngside the prpsed access rads which d nt meet the standards set ut in Interim Advice Nte (IAN) 195/16. The prpsals are cntrary t natinal and lcal planning plicy because they fail t give pririty t pedestrian and cycle mvement with reference t paragraph 35 f NPPF 2012 when cmpared with the extensive investment prpsed fr the new rad alignments. The prpsal is als cntrary t Lcal Plan Plicy 5 which requires prvisin f imprved infrastructure t supprt walking, cycling and equestrians and Plicy 28 and its supprting text, which states that, in general, The pedestrian and cycle netwrk... is indirect... Equestrians and vulnerable users, including thse with mbility difficulties, als need t be taken int accunt.... This statement shws that the planning authrity shws cncern abut the indirectness f active travel infrastructure and recgnises the inadequacy f existing infrastructure alng the A27. Other bjectins, ntably that frm the British Hrse Sciety whse letters f February and June 2018 als repeat their requirement fr a higher standard f infrastructure design which is currently insufficient t meet the requirement fr equestrian infrastructure, with particular reference t the clearance under the A27 flyver, as set ut in Lcal Plan Plicy 5. The design and specificatins fr the prpsed rute are cntrary t the material cnsideratin f IAN195/16 fr reasns described in the accmpanying design review which frms part f this bjectin. We believe that lcal planning and highway authrities shuld agree and meet design standards fr active travel infrastructure t guide relevant develpment prpsals. Hwever, since n such guidance appears t exist fr West Sussex we have relied upn a number f ther well-established surces which are taken n bard as material cnsideratins supprting ur cntentin that the develpment des nt cmply with the develpment plan. Our bjectin wuld be addressed by the fllwing measures: The applicant must submit t the Lcal Planning Authrity in the S.106 and, where applicable, the s.278 Agreements a revised set f prpsals shwing an active travel netwrk fllwing the recmmendatins in the accmpanying reprt that demnstrates with reference t Lcal Plan Plicies 1, 5 and 28 and NPPF 2012 paragraph 35 the priritisatin f access fr peple travelling n ft, cycle and as equestrians; and The applicant must demnstrate with clear drawings specifying the cnstructin methd that all infrastructure intended fr use by pedestrians, cyclists and equestrians will meet the standards set ut in IAN195/16, extended t include rads t be adpted by the Cunty Highway Authrity in the absence f Cunty advice n the matter, and take n bard the advice given in reprt accmpanying this bjectin 5 f 10
4 Inadequacy f prpsed crssing pints at the rundabut which frms the entrance t the prpsal site and failure t prpse a high quality nn-mtrised netwrk that cnnects the site with neighburing areas We bject t the replacement f the Sussex Pad crssing with prpsed pedestrian and cycle crssings at the prpsed rundabut which frms the entrance t the prpsed develpment site and we bject t the failure f the prpsed develpment t prpse a high-quality netwrk f rutes fr pedestrians, equestrians and cyclists thrugh the prpsal site and linking with neighburing areas which, as pinted ut in the WSCC third respnse dated 23 rd January 2018, als intrduces a large number f crssings which will make walking and cycling less cnvenient and unnecessarily expses users t junctin risks. The prpsals as they stand are cntrary t the Natinal Planning Plicy Framewrk (2012) with regard t the requirement (where practicable) t give pririty t pedestrian and cycle mvements. They are als cntrary t Lcal Plan Plicy 5 which states the need fr imprved walking, cycling and equestrian infrastructure assciated with the New Mnks Farm site, and Plicy 28 and its supprting text which states that, in general, The pedestrian and cycle netwrk is indirect, disjinted in parts... Equestrians and vulnerable users, including thse with mbility difficulties, als need t be taken int accunt. This statement shws that the planning authrity recgnises the scpe fr imprved infrastructure alng the A27. Other bjectins, ntably that frm the British Hrse Sciety whse letters f February and June 2018 als repeat their requirement fr a higher standard f infrastructure design which is currently insufficient t meet the requirement fr equestrian infrastructure as set ut in Lcal Plan Plicy 5. Our bjectin wuld be addressed by the fllwing measures: The applicant must submit t the Lcal Planning Authrity in the S.106 and, where applicable, the s.278 Agreements a revised set f prpsals shwing an active travel netwrk fllwing the recmmendatins in the accmpanying reprt that demnstrates with reference t Lcal Plan Plicies 1, 5 and 28 and NPPF 2012 paragraph 35 the priritisatin f access fr peple travelling n ft, cycle and as equestrians. This netwrk must include the fllwing: A revised active travel netwrk centred n a new spine cycle track and adjacent ftway cnstructed t the suth f the prpsed access rad netwrk t prvide direct, cnvenient and high-quality links with fewer rad crssing pints between Old Shreham Tll Bridge and Manr Rad, cnnecting with the existing residential area and prviding a branch t a retained Sussex Pad crssing; The cnversin f the existing signalised crssing immediately east f the A2025/A27/Manr Rad rundabut junctin t a shared r parallel cycle/pedestrian crssing tgether with assciated segregated use tw-way cycle track n the nrthern side f Old Shreham Rad cnnecting, at a safe place, t Manr Rad, with safe, flush transitins t the cycling infrastructure t and frm the existing rundabut; and Prvisin f a cycle cnnectin between Manr Way and Hayley Rad and cnversin f the existing ftpath link frm Orchard Way t Curvins Way t a shared use cycle and ftpath link. Other links (nt illustrated belw) t prvide cnvenient access t the active travel netwrk. 6 f 10
The abve requirements alng with a range f wider issues are illustrated in the map belw and in Figure B (Sectin 14) f the accmpanying reprt. T fully meet ur requirements: The applicant must demnstrate with clear drawings specifying the cnstructin methd that all infrastructure intended fr use by pedestrians, cyclists and equestrians will meet the standards set ut in IAN195/16 and takes n bard the advice given in the reprt accmpanying this bjectin. We supprt the Cuncil s prpsal t use develper cntributins t upgrade the existing crssing f Grinstead Rad at Marsh Barn Lane, hwever we wuld prefer that the crssing includes significant tightening f the gemetries f the staggered junctins t reduce turning speeds and facilitate reprvisin f the crssing n the natural desire line between the tw junctins. 5 Paths in the prpsed cuntry park are sub-standard width and cnstructin We bject t the sub-standard width and / r surface treatments prpsed fr paths and bridges in the prpsed cuntry park. This is cntrary t Lcal Plan plicy 5 which requires an imprvement in the quality f active-travel infrastructure and Plicy 28 and its supprting text that describes the need t imprve the quality f the active travel netwrk. The accmpanying reprt describes sme f the prpsed infrastructure as critical design failures with respect t their intended functin. We further bject t the prpsed use f self-binding gravel as a surfacing treatment as it is unsuitable fr wheelchair users and is subject t weed grwth and incursin f vegetatin, fld damage and degradatin. Our bjectin wuld be addressed by the fllwing measures: All paths described as suitable fr cycling shuld be an abslute minimum useable width f 3.0m. Where paths are cnstrained by vertical features exceeding 60cm, an additinal 50cm 7 f 10
shuld be allwed each side t create the usable width. The minimum width between bridge balustrades shuld be 4.0m; Separate bypassing paths shuld be prvided arund the car park t enable peple walking, running r cycling lps arund the cuntry park t avid mving thrugh the car park - this t minimise cnflict between pedestrians, cyclists and mving vehicles; Prper cnsideratin shuld be given t enabling peple t crss the link rad n ft including t access the bus stp and t enable cyclists t access prper cycle facilities, in rder t make the cuntry park accessible t all; All paths intended fr shared use between cyclists and pedestrians shuld be surfaced using a permeable hard surface that is resilient t flding; and The applicant shuld nt reduce the extent f the prpsed cuntry park walking and cycling netwrk in respnse t this bjectin. 7 Develpment layut des nt place cmmunity uses at the heart f the cmmunity We bject t the failure f the develpment t place the prpsed cmmunity hub and primary schl at the heart f the new and existing cmmunity. This is cntrary t draft NPPF 2018 in which Chapter 8, paragraph 69 states that the planning system can play an imprtant rle in facilitating scial interactin and creating healthy, inclusive cmmunities by prviding fr safe and accessible envirnments cntaining clear and legible pedestrian rutes which encurage the active and cntinual use f public areas. The prpsals d nt meet this material cnsideratin, which may reasnably be interpreted as frming part f Lcal Plan Plicy 1, as fllws: The prpsed hub is at the edge f the prpsed residential develpment and remte frm the existing cmmunity, therefre it wuld nt meet the test f a place that wuld encurage the active and cntinual use f public areas; The prpsed hub is at the edge f the prpsed residential develpment and therefre des nt adequately serve the existing and new cmmunity by virtue f a 10-minute walking radius; and The prpsed hub des nt include the full range f services that wuld be expected within 10 minutes walking radius f peple s hmes, including a cnvenience stre, chemist and pharmacy. Our bjectin wuld be reslved by the fllwing measures: Lcate the prpsed cmmunity hub, including the primary schl, between the prpsed develpment and existing develpment, in a lcatin pssibly t the east f the area f existing public pen space brdering Shadwell s Rad where it can mre easily be accessed n ft, cycle and by a chice f public transprt rutes; and The prpsed hub shuld include adequate cycle parking cnveniently placed t serve t the shps but placed in the carriageway rather than n the ftways (e.g. in a parking bay allcated fr the purpse). Pedestrian and cycling rutes and cycle parking must be demnstrably mre cnvenient than the car parking and 10% f the cycle parking spaces shuld be designed fr adapted cycles, tandems and tricycles. 9 Cycle strage We bject t the prpsed means f prviding cycle parking which is cntrary t Plicy 28 f the Lcal Plan and may be cntrary t current WSCC parking standards last updated in 2010. By reasn that the develpment des nt priritise access by cycle because it des nt make the cycle parking bvius, cnvenient and single-purpse, the prpsals are cntrary t NPPF (2012 and draft 2018). Whilst we acknwledge that the minimum cycle parking standards are referenced in the Design and Access Statement, the residential prpsals d nt make clear the methd f prviding cycle parking except with reference t prpsed garages being 3.0m wide and 5.0m deep r sheds in back gardens. We d nt believe that the garages will be sufficiently wide (with 0.5m left ver each side, assuming a wide car width f 2.0m) t accmmdate cycles 8 f 10
alngside cars, given the ppularity f SUV type vehicles, and sheds will be used fr ther purpses and d nt make cycling cnvenient as a first chice fr shrt jurneys; and Cycle parking is indicated t the nrth f the IKEA stre and will mst likely be prvided t meet WSCC minimum cycle parking standard fr the schl and cmmunity hub uses. Hwever, we d nt believe that the current lcatin f the cycle parking serving the stre meets the bjective f priritising sustainable travel mdes as it is nt cnveniently lcated r in a place where it will be cnstantly seen by passers-by. Our bjectin wuld be addressed by the fllwing measures (which exceed stated plicy): Cycle parking prvided fr the prpsed superstre (utline applicatin) shuld be cnveniently lcated adjacent t the stre entrance / exit, sheltered and with gd natural surveillance. It shuld be placed where it wuld be lgical fr a cyclist t use it, i.e. as clse as practicable t the stre entrance. Cycle parking prvided fr the cmmunity uses including the schl shuld be cnveniently placed where they have gd natural surveillance and are mre cnvenient than the car parking. Staff cycle parking shuld be sheltered frm the weather and secure, and staff shuld have access t shwers and changing facilities. Residential cycle parking shuld be placed where it is mre cnvenient than driving fr shrt trips. Typical lcatins include: On the street in cycle hangars which cntain up t 8 cycles in each, with keys allcated t residents. Residents pay an annual fee fr maintenance f the facility which shuld be waived in the first year. The arrangement wuld ensure that the hangars are used fr cycles nly and nt fr ther purpses f residents chsing; alternatively Wider garages specified t a minimum width f 3.5m t allw space fr cycle strage and access alngside s that the chice t cycle is made as easy and cnvenient as pssible. Cycle parking prvided fr the superstre, schl and cmmunity hub shuld meet the minimum standards set ut in West Sussex Cycle Parking Standards (revised 2010) and shuld include separate, secure cycle parking, changing facilities and shwers fr staff; and Cycle parking prvided fr primary schl children shuld meet the minimum standards and be assciated with a safe netwrk fr cycling that parents feel cnfident allwing their children t use. Failure t make prvisin fr the prpsed bus service t call at a stp directly utside the IKEA stre entrance We bject t the failure f the prpsals t ensure that car dependence is reduced by extending the bus service t the frnt dr f the prpsed IKEA stre (utline applicatin). With respect t the utline applicatin, this is cntrary t the Lcal Plan plicy 5 which requires the prvisin f sustainable transprt infrastructure including imprved public transprt and als cntrary t the NPPF (2012) which requires lcal planning authrities in plicies and decisins t actively manage patterns f grwth t make the fullest pssible use f public transprt Our bjectin wuld be addressed by: Extending the bus rute t the frnt dr f the prpsed IKEA stre s that it is mre cnvenient than driving. The bus stp shuld be accessible t enable peple with wheelchairs t bard and alight and the bus rute shuld be designed t avid cngestin assciated with 9 f 10
the car park. Ideally the buses shuld be capable f carrying IKEA flat-packed furniture taken with passengers; Prviding real-time bus infrmatin bth at the bus stp and within the stre, such as in any café area, t infrm staff and visitrs abut bus services. This wuld als help raise the prfile f buses within the develpment and encurage fewer peple t drive; and Mitigating cntributins shuld be made via the s.106 agreement twards an increase in bus frequency frm ne t tw buses each hur, with ne f the bus rutes each hur making the direct link t Shreham by Sea rather than returning thrugh the estate. The bus service shuld be prmted thrugh the travel plan and wuld assist the bjective f reducing the ptential traffic impact f the prpsals n the A27 and surrunding cmmunity. Guidance n planning and prviding fr buses in urban develpment can be fund here: http://www.ciht.rg.uk/en/dcument-summary/index.cfm/dcid/1d79344d-a8e9-429b- A0C6710299356BCD Yurs sincerely Chris Tdd Planning and Transprt campaigner Brightn and Hve Friends f the Earth, and als n behalf f Bricycles, Cycling UK lcal representatives, The British Hrse Sciety, Shreham-By-Cycle, Sustrans Wrthing C-rdinatr, West Sussex Cycle Frum and Wrthing Cycle Frum. Enclsure: Nn-Mtrised Users Design Review dcument 10 f 10