Planning – Application Comments

Comment Date: Fri 13 Oct 2023

On the basis of the number of residential units proposed on the first and second floor areas (9 in total each having 1 bedroom), a total of 9 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.

No off-street car parking is proposed to serve the development and no further/supporting information has been provided to justify this position (the need for such is clearly outlined within para 8.7 of the JLP SPD). It is however noted that the Site Layout Plan makes reference to 9 vertical bike lockers.

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 59 The Broadway proposes a further 14 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 potential 9 spaces generated by this proposal.

No reference is made to the provision of any dedicated drop-off provision for residents residing in these flats. With no on-street car parking provision on-site, the need for such is considered essential.

Although it is possible that residents could use the servicing area to the rear of the building, this area currently serves the ground floor retail/commercial units. Therefore, were residents to start parking in this area for drop-off/collection or alternatively for home-shopping deliveries etc then service vehicles associated with the commercial units could be displaced onto Horn Lane impacting upon both vehicular and pedestrian movements along this route. Alternatively, if residents were prevented from using this area for drop-off then it is likely that it would be they who would park indiscriminately on Horn Lane for the purposes of loading/unloading etc.

Either way, the lack of drop-off provision is likely to give way to indiscriminate parking taking place on Horn Lane giving rise to highway safety concerns considering how busy this road is and the high number of pedestrian movements that occur within this area.

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 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.

If however, you are minded to grant in support of this application then it should be noted that the development would be excluded from the CPZ that is in operation within those residential streets immediately surrounding the site.

Comment Date: Thu 12 Oct 2023

LLFA Consultation response 23.01301.GP3.pdf

Comment Date: Fri 06 Oct 2023

Public Protection Service does not have a comment to make about this application.