Dear Cllr Spikings

Re: 21/00995/FM | Proposed primary care centre, new access and associated facilities | Land W of The Gardens Edward Benefer Way King's Lynn Norfolk

I am writing to you to update the planning committee on the objections of KLWNBUG, the Norfolk and Fens Cycling Campaign to the above named application because:

1. While we are not yet clear what the declaration of a Climate Emergency by the Borough Council means for the planning process, this seems a clear early example of a pre-emergency carbon-emitting-transport-centred plan being submitted to the council, failing to comply with several sustainability-related planning policies and mystifyingly being given a recommendation for approval by planning offices who seem to have undervalued and, in one case, misread some great planning policies adopted by the council or its colleagues in national government.

This is a great opportunity for you as councillors to show that you are serious that the Climate Emergency does not mean a continuation of development as normal and that you really want developers to build back greener in King’s Lynn and not keep foisting the same old stuff onto the borough, that our residents deserve the same level of care as nearby cities, or perhaps even greater care due to our vulnerable coastal location.

Please reject this version of the application due to the following existing policies:

2. Most seriously, the proposed development does not comply with paragraph 112 of the National Planning Policy Framework which requires developments to:

Give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and [...]

Create places that are safe, secure and attractive –which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards

The development is shown as accessed by a wide-mouth turning off the A1078 Edward Benefer Way that completely interrupts National Cycle Network Route 1 (NCN1) with an uncontrolled crossing. This is potentially lethal and we are shocked and disappointed that one of the town’s NHS primary care providers would propose such an unhealthy thing.

The development is forecast to generate a two-lane traffic flow of hundreds of vehicles a day to/from a 40mph road, so according to Table 10-2 of Local Transport Note 1/20, this should be a signal or grade-separated crossing. Here is a copy of Table 10-2:

We do not believe that this fundamental design problem will be solved during the section 278 process, based on past experience with other developments around town.

In particular, simply lowering the posted speed limit to 30mph for another few metres, as discussed in recent correspondence between the applicant and NCC Highways will surely not be sufficient to reduce the actual speed of traffic. This section of A1078 has long had a 40mph limit and looks like it, with a wide straight design, at the foot of a slight downhill slope towards town and with a wide roadside “clear zone” typical of a 40mph road. The section immediately west of this point was recently widened from 2 to 4+1 lanes through the Hamburg Way junction, which has further increased average motor vehicle speeds. If this speed increase is to be reversed, with further narrowing conducted along the section and the “clear zone” replanted with shrubs, then we are surprised but would welcome it, but that has not been discussed on the application file.

Dropped kerbs and a priority crossing as mentioned in the report would be inadequate for National Cycle Route 1. The current national standard guidance is that the cycleway should be level and continuous. If you are minded to allow this application, the access should rise to the level of the cycleway for the crossing, so please delete proposed condition 21 on gradient in order to allow the junction to conform to current Department for Transport design guidance. Gradients can and should be agreed as part of the detailed highway design, so proposed condition 19 covers this already.

Within the proposed development, there is no priority to cycle movements, with no priority route to the cycle parking, and it does nothing to minimise conflicts between cyclists and vehicles. The layout needs a fundamental redesign, possibly to align both walking/cycling entrance and the main building entrances with the edge of the site furthest from the motor vehicle entrance, unravelling the routes so that they do not conflict. As far as I know, this cannot be changed by condition, or addressed during the s278 process, so means you should refuse this application.

3. The application does not comply with paragraph 104 sections (c) and (d) of the National Planning Policy Framework which requires that:

• opportunities to promote walking, cycling and public transport use are identified and pursued;
• the environmental impacts of traffic and transport infrastructure are identified, assessed and taken into account – including appropriate opportunities for avoiding and mitigating any adverse effects, and for net environmental gains.

While section 9 of the Transport Assessment identifies some opportunities, they are not pursued and the environmental impacts do not seem to be assessed. This omission cannot be secured by condition, so we urge you to refuse this application until such time as the opportunities are pursued and the environmental impacts of transport assessed.

4. This application also does not comply with the Borough Council Core Strategy Policy on Transport, due to failing to meet the Parking Standards for Norfolk 2007 revised 2020. While we welcome the inclusion of stands giving parking for some cycles, I draw your attention to these failings:

• There is not enough cycle parking. The applicant’s own Transport Assessment calculates that 9 staff cycle spaces and 36 visitor spaces are required for a building of this type and size (not checked) but the drawings dated 27 October 2021 show only 21 spaces in total, with cycles parked much closer together than the 1050mm per pair shown in Diagram 1b of the Parking Standards, so we strongly suspect that a substandard type of parking is being proposed. We estimate that the space allocated to cycle parking is only large enough for about 10 cycles if the spaces were standard size. The officers appear to misread the parking standards on this matter: the 45 cycle spaces are a minimum requirement, not a maximum.
• The cycle parking does not satisfy the general requirements on Location and Design on page 2 of the parking standards. Racks at the far side of the car park from the road are not "more convenient than car parking" when further from the door than many car spaces, nor are they "under effective surveillance" when hidden up the side of the building, and nor are they "where motor vehicle access is limited to reduce risk of organised theft" as they are directly next to the car park.
• The cycle parking does not satisfy the Signage requirements on page 3 of the parking standards. Those say that the cycle parking should be "obvious and well signed" with a "clear, unobstructed route to parking facility" and there seems no evidence of either of those. In fact, the drawings dated 27 October 2021 show a narrow path used as shared walking/cycling access from NCN1 obstructed by a tree in the middle of the path.
• There does not appear to be any provision at all for cycle parking near the staff entrance. Expecting staff to use the visitor parking is obviously less convenient than the dedicated staff car park and also increases the risk of damage to staff cycles. This again does not satisfy the general requirements of the Parking Standards.

These defects can be secured with conditions, but we ask you to consider whether the space allocated for the cycle park only being large enough for 10 cycles means it will not be possible to include standard parking for 45 cycles and so the application should be refused.

We urge you to refuse permission for the development until such time as it complies with the above policies, with special regard to National Planning Policy Framework paragraph 111 which says “Development should [...] be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety.” Please do not accept this potentially-lethal junction design, else you will share the blame with St James Medical Practice for the casualties that occur here in future.

Thank you for your attention to these details.

Yours sincerely,

[sent electronically]

MJ Ray

Notes

This application was discussed in September Consultations and October Consultations but since our October meeting, NCC Highways have withdrawn their objection and it will be decided by borough councillors on Monday 8 November, before KLWNBUG's November meeting. The deciding planning meeting will be held in Lynn Town Hall at 9.30am and should be streamed on the borough council's YouTube page.