23/01299/GP3
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Change of use of first floor retail storage area (Class E) to 14no. flats (Class C3)
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59 The Broadway Plymouth PL9 7AF


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Highway Authority
Comment Date: Tue 10 Oct 2023
Further to my earlier highway consultation response it should be noted that if you are minded to grant in favour of this application then the development would be excluded from obtaining permits for the controlled parking zone that is in operation within this area.Comment Date: Wed 04 Oct 2023
On the basis of the number of residential units proposed on the first floor area (14 in total) and their size (8 x two bed and 6 x bed units), a total of around 22 off-street car parking spaces would be required to serve the development based upon the application of the indicative car parking standards outlined within the JLP SPD. At the very minimum the Local Highway Authority would expect to see 14 spaces provided (1 space per unit).No off-street car parking is proposed to serve the development and instead the applicant refers to encouraging residents to use sustainable modes of transport as an alternative to the private car (walking, cycling, public transport). Reference is also made to the potential use of the nearby public car park which serves the Broadway Local Centre to cater for visitors to the development. In order to encourage cycling, a total of 22 secure and covered cycle parking spaces are proposed.
Although the LHA accept that the site is located in what could be described as a relatively sustainable location, there is still likely to be considerable reliance by occupiers of the proposed flats on the use of the private car, particularly in respect of employment-related trips.
On the basis that there is a daily charge of £3.30 per day or alternatively a season ticket can be purchased for the sum of £440 per year, residents of the flats are unlikely to consider using the existing public car park serving the Broadway and instead are likely to be tempted to park kerbside in existing residential streets surrounding the site. Whilst it is acknowledged that those streets immediately surrounding the Ridgeway are subject to a mixture of on-street parking restrictions through a combination of double yellow lines and limited waiting, there are lengths of residential kerbside within easy walking distance of the site (less than 400m) where there are no such parking restrictions in place (western section of Mountbatten Way, Berry Park Road).
It is the view of the LHA that in view of the lack of car parking dedicated to serve the flats that residents would be likely to park in these streets, adding to existing levels of kerbside car parking that already takes place and potentially displacing vehicles of existing residents.
In addition, it is noted that this is one of two recently submitted applications for the changes of use from commercial to residential at the Ridgeway. The second application at 24 Broadway proposes a further 9 flats resulting in a cumulative total of 23 units, again with no car parking. As such, the demand for on-street car parking would be considerable and far in excess of the numbers mentioned above if both applications were permitted.
Furthermore, with no car parking or drop-off provision located on the southern side of the building there is the very real likelihood of residents/visitors parking on the existing double yellow lines/zig zag markings on Horn Lane for the purposes of drop-off/collection, home shopping deliveries etc. Vehicles parked in such a location (particularly on the zig-zag markings for the zebra crossing) would undoubtedly be a cause for concern from a highway safety perspective. There could also be the possibility of such vehicles parking in the bus stop on Horn Cross Road, thereby impacting upon existing bus movements.
In view of the concerns with this application as outlined above, I would have to recommend this application for refusal for the following reasons:
Inadequate Provision of Parking
No provision has been proposed for the parking of cars of persons residing at or visiting the development hereby proposed. Vehicles used by such persons would therefore have to park on the public highway adding to the existing on-street kerbside car parking difficulties already experienced within the local area which would interfere with the free flow of traffic on the local road network and give rise to conditions likely to be detrimental to public and highway safety which is contrary to the adopted guidance contained within the Supplementary Planning Document (July 2020) and Policy DEV29 of the Plymouth and South West Devon JLP (March 2019).
Lack of Loading/Unloading Provision
No adequate provision is proposed to be made for the loading/unloading of vehicles making deliveries to the development hereby proposed. Without dedicated provision (particularly on the southern side of the building) such vehicles would therefore have to park indiscriminately on the adopted highway (Horn Lane) giving rise to conditions likely to cause:
(a) Prejudice to public and highway safety;
(b) Interference with the free flow of traffic on the highway;
(c) Unwarranted hazard to vehicular and pedestrian traffic
which is contrary to Policy DEV29 of the Plymouth and South West Devon JLP (March 2019) and Paragraph 108 of the NPPF Feb 2019.
Scott Smy
Transport Development Coordinator
Lead Local Flood Authority
Comment Date: Mon 09 Oct 2023
The Broadway EDG23.001-FRSR-039.pdfPublic Protection Service
Comment Date: Fri 29 Sep 2023
947376.pdf