Planning – Application Comments

Comment Date: Thu 21 Dec 2023

The Broadway EDG23.001-FRSR-055.pdf

Comment Date: Wed 20 Dec 2023

948710 Consultation Response 2.pdf

Comment Date: Fri 22 Dec 2023

Plymouth City Council
Strategic Planning & Infrastructure

Transport Planning Team
Ext: 01752 307813
Date: 13th December 2023
Sam Lewis
Development Management
Strategic Planning & Infrastructure
Floor 2
Ballard House

Dear Sam

Highway Authority Consultation Response to a Planning Application


APPLICATION NO: 23/01643/GP3

SITE: 59 THE BROADWAY, PLYMOUTH

DEVELOPMENT: Change of use of first floor retail storage area (Class E) to 14no. flats (Class C3)


Observations:

My observations on this application will be similar to those made in respect of an earlier application submitted for the same scale of development on the same site (app no 23/01299/GP3), with the only difference between the schemes (from a transport viewpoint) being the allocation of 5 car parking spaces to the scheme.

Whilst the provision of 5 car parking spaces allocated to the scheme is welcomed, it does little to address the overall car parking demand associated with the proposal. Based upon the indicative parking standards included within the JLP SPD, around 22 spaces would be required to serve the development although as stated previously, a minimum provision of 14 spaces would be considered to be acceptable to the LHA. Therefore, on the basis of 5 spaces being provided there is still a shortfall of 9 spaces.

Furthermore, it would appear that the 5 spaces now allocated to the scheme are existing spaces accessed off a service lane which runs to the north of The Broadway. It is not currently clear whom these existing spaces serve but if they are already in use, then allocating these 5 spaces to the scheme will simply displace existing vehicles who currently use these spaces, elsewhere (possibly on-street). On this basis it could be argued that the development hasn't, in any way, mitigated it's impact in terms of car parking supply and demand, thereby leading to further vehicles parking in the existing residential streets just a short walk from The Broadway.

I would also wish to reiterate the concerns raised previously regarding the lack of dedicated loading/unloading provision for home shopping deliveries etc and how the lack of such could lead to service vehicles parking in the bus stop on Horn Cross Road. The applicant has referred to the use of a loading bay accessed directly off Horn Cross Road but I can confirm that there is no such facility, only a bus stop as mentioned above.

Recommendation:

The Highway Authority recommends that planning permission should be refused for the following reasons:-

Inadequate Provision of Parking
Inadequate 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) and Paragraph 108 of the NPPF Feb 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

Officer authorised to sign on behalf of the Service
Director for Strategic Planning & Infrastructure