First of all, I repeat my objection to this application being determined before the cancelled public consultation event from last March has been rescheduled and held.
More currently, on a similar topic, I note that the officer report and recommendation had not been added to the online planning system by 3pm on Monday 29 March, so anyone who has requested "Track this application" by email from that system, rather than paper letters, will not have been notified and had opportunity to comment on the recommendation. Is that allowed?
If you are still minded to determine this application without that public consultation:
KLWNBUG The Norfolk and Fens Cycling Campaign sustains its objections on the grounds of highway safety. We do not have confidence in planning conditions to secure design changes of the scale required because they will be constrained by the aspects that have been approved. This view is based on the recent experiences at NORA where even obvious minor amendments such as removing 2m gaps across cycleways took years to achieve, so we ask you to REFUSE this application on grounds of Borough Core Strategy Policy CS11 Transport until such time as full correct and compliant safe transport plans are submitted.
Furthermore, the report in front of you is mistaken to say (in paragraph 6 of its conclusion) that "there would be enhancement to walking and cycling routes, including the pedestrian / cycle bridge over the railway, which again would be a benefit to those beyond the application site". While there is a new bridge, that is shared with motor vehicles with the pollution and ever-present risk of cycleway incursions. The current active travel bridge is more direct for more people and seriously negative changes are proposed to that one.
I am not sure what analysis the officer has performed to reach that mistaken view, because applying the Department for Transport Level of Service tool from Appendix A of Local Transport Note 1/20 to the proposed plans leads us to expect a 20% reduction in service level on the current north-south route and a slightly smaller reduction on the east-west route. While some changes may be secured by conditions, the report should assess what is proposed and not what may be possible.
Making the routes about 20% worse is not an enhancement and so the claim in the report is not justified.
This is a significant transport design flaw which we feel requires serious revision of the scheme design, not merely minor changes to meet conditions. As such, we ask you to refuse this application at this time on grounds of the Borough Core Strategy Policy on Transport.
Nevertheless, if you approve it, we urge you to amend condition 12 to require that the footways and cycleways must be complete to the highways department's satisfaction prior to occupation of the first dwelling of a phase.
Reason: When the final dwelling is occupied, it is often too late to change habits already formed by most of the earlier residents, who may have moved in months previously, long before safe routes for walking and cycling were completed.
And we urge you to amend condition 29 to include exceeding 2500 AADT as an alternative trigger for intervention to bring motor traffic movements back beneath that level, for reasons of highway safety across two major active travel corridors and past the schools.
Reason: We doubt whether the applicant is confident in their own transport assessment because they have provided cycleways alongside 20mph roads, which is normally only done for more than 2500 AADT vehicle movements.
Thank you for your attention and I await your response with interest.