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Warrington Unitary Development Plan - Revised Deposit Draft
Warrington Cycle Campaign Objections


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Summary

Warrington’s first Unitary Development Plan UDP has now been published for it's second formal round of public consultation. There have been some changes for the better, notably the acceptance of maximum parking standards, though the wording of the policies is still ambiguous in this respect. Unfortunately, the revised deposit policy on cycling still seeks to undermine the council's excellent cycling strategy.

This document summarises the objections to changes in the plan that the cycle campaign has submitted.

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Part 1 Policies: The UDP Strategy

OBJECT: TCD2, TCD3, TCD4, TCD5, TCD6

These policies are ambiguously worded in the context of maximum parking standards - and could be misinterpreted to mean that the maximum must be provided, rather than not exceeded (see parking policy).

Replace the words:

make provision for car parking in accordance with the Council's approved maximum parking standards,
with:
does not provide car parking spaces in excess of the Council's approved maximum parking standards,

OBJECT: EMP2

Developing OMEGA at all conflicts with the policy of a low housing land provision. Bringing 12000 new jobs would be incompatible with a policy of restricting house building. It seems absurd therefore for this policy to be relaxed to include telecommunications while the rest of the UDP is being changed to restrict the supply of housing land (via the removal of GRN2). In this context any development at OMEGA is bound to generate unsustainable travel patterns.

Such development would be much better located in a town center, urban regeneration site, or a mixed-use development.

Remove the added sentence:

Although telecommunications is not specifically listed within this grouping, the Council is keen to promote the full range of Information and Communication Technology and will give favourable consideration to proposals from telecoms businesses alongside these target sectors
Note that we still believe that the entire policy should be deleted in line with our objection: O / EMP2 / 496 / 11890

SUPPORT: GRN2

We support the removal of this policy.

We would like to withdraw our objection: O / GRN2 / 496 / 12804

OBJECT: DCS1

The changes to sections 1 and 4 weaken the commitment to high-density, mixed-use, and socially mixed development.

Warrington has many low-density exclusively residential suburbs. The UDP should be actively promoting a change in character and quality of such areas, rather than protecting them.

Sections 1 and 4 should revert to the wording in the first draft UDP.

1. it should not cause unreasonable harm to the amenities of people living nearby;

4. it should make efficient use of land in terms of location and density of development and intensity of use, and, the mixed mix of uses;

OBJECT: DCS3

Section 13 undermines the commitment to high-density, mixed-use, and socially inclusive development.

Warrington has many low-density exclusively residential suburbs. The UDP should be actively promoting a change in character and quality of such areas, rather than protecting them. This section could be used, for example, to prevent the provision of affordable housing in areas where the existing character is that of an executive housing estate.

Remove sections 13:

13. the need to protect and enhance the quality, attractiveness and character of residential areas;

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Part 2 Policies: Transport Integration

OBJECT: LUT4

We oppose the change to the first section in LUT4. It is important to safeguard the lines of existing rights of way. If any changes are made these should result in more direct and convenient routes for pedestrians, rather than lengthy diversions.

Remove the sentence added to section 1:

In specific cases there may be a need to divert public footpaths within a landscape setting to provide an appropriate alignment within the structure of a development.

OBJECT: LUT12

Warrington Borough's adopted Cycle Strategy (policy CP7) requires all land use development proposals to be subject to a cycle audit to ensure that schemes include improvements to, or at least have no negative impact on the coherence, directness, safety, attractiveness and comfort of routes used by cyclists. The procedure for undertaking cycle audits is described in:

Guidelines for Cycle Audit and Cycle Review - Institution of Highways and Transportation/ Department of the Environment, Transport and the Regions/ The Scottish Office/ The Welsh Office/ DOE Northern Ireland. Available from the Institution of Highways and Transportation (IHT)
Although reason & explanation 6 mentions "user audit" it is unclear what this means. Many developers will be unaware of the IHT guidelines, so it is important that the IHT guidelines are explicitly referenced in the UDP.

Replace Reason and Explanation 6 with:

6. For every application, an integral part of the transport assessment process will be both user and safety audits. This will include a full cycle audit to ensure that schemes include improvements to, or at least have no negative impact on the coherence, directness, safety, attractiveness and comfort of routes used by cyclists. The procedure for undertaking cycle audits is described in:
Guidelines for Cycle Audit and Cycle Review - Institution of Highways and Transportation/ Department of the Environment, Transport and the Regions/ The Scottish Office/ The Welsh Office/ DOE Northern Ireland. Available from the Institution of Highways and Transportation (IHT)

OBJECT: LUT20

The first paragraph contradicts PPG3 and PPG13. These state that policy should not be expressed as minimum standards, and should not require developers to provide more spaces than they themselves wish.

Reason and explanation 4 should be removed as it effectively undermines the whole policy. If a developer is seeking to provide more than the maximum limits that is evidence that the development is in an unsustainable location.

Reason and explanation 6 makes no sense in the context of maximum standards. This sort of development should be positively encouraged, rather than have to satisfy more rigorous demands.

Change the wording of the first paragraph to:

Developments will not be permitted to provide for parking in excess of the Council's maximum parking standards. There are no minimum standards for development, apart from parking for disabled people.
Delete reason and explanation 4.

Delete reason and explanation 6.

OBJECT: LUT21

Reason and explanation 3 effectively undermines the whole policy.

The wording must be much stronger and require that the parking actually is removed after one year rather than just a travel plan implemented in the vague hope that the parking spaces will become redundant at some point in the future. This will place a real incentive for developers to produce an effective travel plan rather than "go through the motions" as a backdoor method of circumventing the councils maximum limits.

Change reason and explanation 3 to:

For expansion of car parking above the maximum level Travel Plans must be developed, and approved, by the authority before planning approval is granted. Targets and actions will need to be agreed and incorporated within the travel plan. The action plan must be fully operational and the additional parking spaces must be removed within 12 months of the opening of expanded car park areas. Monitoring arrangements and reporting will be the responsibility of the developer and will be agreed with the Council.

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OBJECT: HOU2

The 4th bullet point of section 2 is inconsistent with the policy objective of achieving higher density development.

The 4th bullet point of section 7 is ambiguously worded in the context of maximum parking standards - and could be misinterpreted to mean that the maximum must be provided, rather than not exceeded. Secure cycle storage is not a matter of providing space in the site layout, but of providing the physical facilities such as cycle lockers or dedicated garage space.

Remove the 4th bullet point from section 2:

  • the amount of space around buildings and the proportion of the site and plots within it occupied by buildings and hard surfacing;

Replace the 4th bullet point from section 7:

  • provide for car parking in accordance with the Council's maximum standards, and take into account the need for cycle storage space.
With:
  • does not provide car parking spaces in excess of the Councils approved maximum parking standards.
  • provides sufficient secure convenient indoor cycle storage for all residents of a home to store their bicycles.

SUPPORT: HOU5

We now fully support this policy as it has been reworded so we would like to withdraw our objection to the first deposit draft: O / HOU5 / 496 / 11876

OBJECT: HOU15

Reason & explanation 2 refers to affordable homes in neighbouring areas within acceptable travelling distance, in meeting at least some categories of housing need. Acceptable travel should only consider sustainable modes (walking, cycling and public transport). This effectively rules out any areas outside the borough, so it is entirely appropriate for any needs study to only consider affordable housing within Warrington.

Remove the following words from to reason & explanation 2:

or affordable homes in neighbouring areas within acceptable travelling distance, in meeting at least some categories of housing need. It is recognised that the effects of local and sub-regional housing markets need to be better understood and the Council will work closely with neighbouring authorities to research this issue further.

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Part 2 Policies: Town Centres and Retail Development

OBJECT: TCD12

The policy is ambiguously worded in the context of maximum parking standards - and could be misinterpreted to mean that the maximum must be provided, rather than not exceeded.

There is also a perverse exception, in that the policy permits the maximum standard to be exceeded in cases where there are no direct sales to the public.

Replace section 4:

provision for car parking is made in relation to accordance with the Council's approved maximum standards for the retail floorspace unless all sales take place via an ordering system, with no direct sales to the public from the premises;
with:
does not provide car parking spaces in excess of the Council's approved maximum parking standards;

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Part 2 Policies: Economic Development

OBJECT: EMP3

SUPPORT: EMP4

We support the changes to section 1 of the policy:

in accordance with the transport priorities set out in policies LUT1 and LUT2 to prioritise walking, public transport and cycling and minimise new trips by car,

This satisfies our objection to the first deposit draft.
We would like to withdraw objection: O / EMP4 / 496 / 12802

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Appendix 5: Parking Standards

OBJECT: Appendix 5

The second sentence of section 2 has been changed from:

Developers will not normally be required to provide more spaces than they themselves require,
to:
Developers will not normally be required or permitted to provide more spaces than the specified maxima,
This seems to imply that sometimes developers may be required to provide excessive parking. This should be reworded for clarity and to comply with PPG3.

Change the wording of the second sentence of section 2 (Maximum Standards) to:

Developers will not be required to provide more spaces than they themselves wish, nor will they be permitted to provide more spaces than the specified maxima,

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References

1. Guidelines for Cycle Audit and Cycle Review, Department of the Environment Transport and the Regions, September 1998

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Links

UDP: Warrrington Unitary Development Plan http://www.warrington.gov.uk/news/udp.htm
LTP: Warrrington Local Transport Plan http://www.warrington.gov.uk/council/pub_ltp.htm
LTP proposed cycle network http://www.warrington.gov.uk/publications/ltp/CyclePlan.pdf
Warrington Cycle Strategy http://www.ben.lukey.care4free.net/reports/wbc-cyclestrat.doc
Future Warrington: Warrington Community Plan http://www.warrington.gov.uk/council/pledges_comm_plan.htm
Our objections to the first draft deposit UDP http://www.warringtoncyclecampaign.co.uk/reports/UDP/objections-draft1.htm
Our comments on UDP strategic issues http://www.ben.lukey.care4free.net/reports/udp-stratcomment.doc
PPG13: Planning policy guidance - Transport http://www.planning.dtlr.gov.uk/ppg/ppg13/index.htm
PPG3: Planning policy guidance - Housing http://www.planning.dtlr.gov.uk/ppg3/index.htm
RPG13: Regional Planning Guidance for the North West http://www.nwrpg-panel.gov.uk/
By Design: Urban design in the planning system: towards better practice http://www.planning.dltr.gov.uk/bydesign/html/index.htm

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Updated 16th December 2002
Pete Owens

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