This article was published in 2006, in Newsletter 64.
In Newsletter 56 we published an article summarising a number of issues relating to cycle parking provision. Any cyclist in Cambridge will be aware of the shortage of cycle parking virtually everywhere in Cambridge, both in public and private areas.
Since then another major development has occurred on this topic: the review of the Cambridge Local Plan.
What is the Local Plan?
The Cambridge Local Plan sets out policies and site specific proposals for the development and use of land in Cambridge. These are then used to develop schemes and assess planning applications, through a process known as Development Control.
Over the last few years, Cambridge City Council has been working to revise the Local Plan. During this time, we have submitted letters both supporting and objecting to a range of topics within the drafts as they have been issued for consultation.
These letters are available on our website (or upon request, via our usual contact details), at: www.camcycle.org.uk/campaigning/letters/ – see the letters with references NA03011b, C05003, P05007, NA05008 and C05030.
In some cases, we have received reassurances or proposed changes to the draft, enabling us to withdraw various objections. However, the Cycle Parking Standards, which form part of the Local Plan, have remained problematic in areas.
What are the Cycle Parking Standards?
The Cycle Parking Standards are one of the main areas of the plan which affect cyclists. They set out the Council’s minimum requirements in terms of cycle parking for new developments and changes in use.
Like the rest of the Local Plan, they have no relevance to levels of on-street provision or existing developments over which no changes are planned. These cases are simply beyond the scope of the Local Plan.
These Standards have been amended three times in the last ten years, and the previous versions can be seen on our website. (As always, members can request printed copies via our usual contact details.)
The Cycle Parking Standards set out (for new developments or changes in use) two things: firstly, the amount of cycle parking required (i.e. the number of spaces), and secondly ancillary design principles (such as closeness to the development and the need to ensure that stands enable the frame of the bike to be locked to the stand).
The number of cycle parking spaces required is based on the type of development and how much space is assigned for that usage. Examples are:
- Guest houses and hotels: 1 space for every 2 members of staff and 2 spaces for every 10 bedrooms
- Food retail: 1 space per 25 m2 floor area up to 1500 m2 and thereafter 1 per 75 m2
- Offices: 1 space for every 30 m2 gross floor area, to include some visitor parking
and so on. There are in fact 21 categories of usage, so it is clear that the Standards are comprehensive.
The Cycle Parking Subgroup again discussed the Standards at two meetings in November. In general, we have been quite clear that the Standards are overall pretty good, although there were a number of areas which we wanted to see improved (see below).
The Campaign’s main concern over the last few years has been the matter of enforcement of the Standards. It had become quite clear that there has been no effective mechanism, as far as we can see, for enforcement of the Standards. Many planning applications had been approved for which the levels of cycle parking were clearly below what was required by the Standards.
In some cases, this ignoring of the Standards by the City Council themselves has been on the basis that the levels required, particularly for large developments, were apparently in some cases excessive. This therefore led, in the latest consultation draft, to lowering in some areas of the Standards of levels required for some usages, and the introduction of a new principle of flexibility for a multiple-purpose site, where effectively duplication of provision might have resulted.
We take the view that we would rather see realistic levels proposed in a set of enforceable Standards, rather than a document which is simply ignored when the planning authority feels like it.
On these grounds, we have accepted this principle of flexibility. However, we have done so effectively on the basis that we feel that the City Council now has no let-out clause when developments are proposed. We will be ever-more vigilant for new developments, and will have no hesitation in immediately objecting to proposed developments which do not meet the Standards which come out of the Local Plan Inquiry process.
The difficulty with the Local Plan Inquiry process has been that the process of enforcement is out of the scope of the Local Plan itself.
Of course, this makes a mockery of the existence of Standards: what point is there of setting standards if their enforcement is weak?
Local Plan Inquiry hearing
On 22 November 2005 the Co-ordinator, Martin Lucas-Smith, appeared as our representative to the Local Plan Inquiry hearing. This was our opportunity to debate, in front of the Local Plan Inspector, our outstanding objections to the Standards.
This provided the opportunity to demonstrate the validity of our objections, and we hope the arguments put have been sufficiently strong that the Inspector will accept them and require the City Council to amend the Standards accordingly.
The Officer put forward to represent the Council’s case against our objections was, ironically, the Walking & Cycling Development & Promotion Officer, with whom the Campaign has a good working relationship and who has often been very helpful in taking matters forward on our behalf.
The Cycle Parking Subgroup assembled a preparatory briefing which was used at the Inquiry. This has full details of our arguments and is available online from www.camcycle.org.uk/campaigning/letters/2005/#C06001 or on request.
The concerns we put forward were as follows:
1: Enforcement of the existing Standards
We started by setting out a list of examples of cases where enforcement has been defective, such as the Grand Arcade (fewer spaces than required, and in the wrong location, round the back of the building), Bradwell’s Court (absolutely no parking being provided for visitors in what arguably is the area across the whole of Cambridge with the highest demand for cycle parking after the railway station), the new pubs on Regent Street (where the demand for cycle parking is quite clear, given the presence of ‘don’t park here’ signs!), Cambridge Leisure Park, flats fronting Cherry Hinton Road (which have ‘wheel bender’ stands, completely forbidden by the Standards) and so on.
Whilst we had to accept that the matter of enforcement was technically beyond the scope of the Local Plan itself, this quite clearly set out the background for the rest of the discussion.
2: Use of a pro-forma to aid compliance
We suggested that developers should have to submit a council-supplied form as a means to clarify requirements and to demonstrate that the levels of cycle parking proposed meet the Standards. At present, given the above examples, it is clear that existing procedures are inadequate.
Such a pro-forma would take the format of a simple form containing the same table as the Standards themselves, but with an additional two columns to enable (i) the category and gross floor area and (ii) the resulting number of cycle parking spaces to be entered. It is then a simple matter to calculate and demonstrate the total requirement which must be provided (with a ‘total’ box at the end), and thus the required space allocated and planned for from the start of the planning process.
The Council argued (in their written rebuttal of our objection) against such a form on the basis that:
The suggested pro-forma, which would require developers to indicate how much cycle parking they were providing for each category, would only be appropriate for larger developments and this information could be requested on a case-by-case basis.
It was not explained why such a pro-forma ‘would only be appropriate for larger developments,’ nor are we at all convinced that this would lead to effective enforcement. There already exists a form, one which is grossly inadequate:
We felt this rather demolished the Council’s case, and at the Inquiry, the City Council appeared to have no come-back on this. We hope that a sensible pro-forma system can be implemented, as that should make everyone’s job simpler and easier.
3. Revision of the Standards downwards in places
We discussed here the issue of flexibility. We had no choice here really but to accept the Council’s assurances that this should lead to more effective enforcement as the Standards would be more ‘realistic’. However, we expressed concerns that no guidance on what ‘flexibility’ would mean in practice.
We also questioned why the student cycle parking Standards were also proposed to be downgraded, and that the inclusion of cycle parking ‘on merit’ for some uses is unnecessarily vague.
4. That cycle parking should be closer than any car parking to the entrance of a development
We saw no adequate reason why this could not be part of the Standards, as a means to promote and encourage cycling. (We accepted that disabled parking rightly could be closer.)
5. Commuted payments
Whilst the Campaign has concerns about the use of commuted payments, due to the lack of clarity involved, we are concerned that developers in the City Centre are demonstrably being ‘let off’ provision of cycle parking in cases where there is supposedly no space. This is despite the City Centre being the area where cycle parking is most needed.
The Council instead proposed the ‘flexibility’ clause. Our objection could not be pursued here as we did not propose new wording, because we wanted the issue explored rather than setting out a firm proposal one way or the other.
6. Inclusion of high-capacity stands
The draft standards do not define the conditions under which high-capacity stands could be used. The Council’s Proof merely states:
These stands are included to allow the developer some flexibility where space is at a premium, for example in the Historic Core Area.
We feel there are only very limited cases in which these should be used. Such stands are useful in situations where there is genuinely little space. However, it is our considered view that standard ‘Rounded A’ or ‘Sheffield Stands’ are preferable where there is space, a view demonstrated by their widespread use across the city and beyond.
We proposed the following wording, which would remove ambiguity:
‘It is acceptable to use high-capacity stands only when no on-site car parking is provided. The number of such stands must not exceed 50% of the total cycle parking provided.’
We hope that such wording, or something along the same lines, can be accepted.
We also argued against the inclusion of a diagram of high-capacity stands, given that their use would be quite rare. This would be best included within a ‘how to do cycle parking document’, something which we would like to see produced.
It is not clear what the next steps are, but we presume that an Inspector’s Report will be published at some point in the coming months. We will of course report, through these pages, what happens next.
All members are warmly invited to the next meeting of the Cycle Parking Subgroup, at 8 pm on Wednesday 8 March at 100 Thoday Street. We will cover any cycle-parking related issues that have arisen. Campaigning to get residential cycle parking in the Romsey area will be amongst the topics under consideration.