Greenwich Society submission to Royal Borough of Greenwich draft Transport Strategy consultation
The Society welcomes the release of RBG’s draft Transport Strategy and broadly supports its stated objectives. We believe that our submission supports the goals set out in the consultative document and avoids some of the challenges caused by the LTN which was in place during 2020-2021.
Our proposals address residents’ serious concerns around the level of traffic congestion in steep and narrow streets both east and west of Greenwich Park, and the resultant issues of safety and pollution, in a way which is acceptable and beneficial to most local residents. (Informal traffic observations indicate that more than 40% of vehicles driving up Croom’s Hill on a Friday afternoon were vans or trucks.)
Our proposals have been informed by our review of the scheme adopted successfully in South Fulham by the London Borough of Hammersmith and Fulham. where many objectives were similar to those outlined in the RBG Draft Strategy and there is data evidencing the success of the measures introduced and with no apparent negative effect on other areas. We would encourage the RBG Transport Strategy team to review this scheme.
While acknowledging the necessity for a Borough-wide strategy, members of the Greenwich Society have their primary interest in the area approximately within SE10. Therefore this submission takes account of the potential to meet the strategic goals within these streets and suggests some of the action which might follow approval of the Strategy.
In summary, we propose that a camera-based Automatic Number Plate Recognition scheme (ANPR) with specific exemptions is adopted to limit traffic, and that accurate data on traffic flow and pollution is collected to evaluate the scheme over a suitable period.
Taking the themes of the Draft Transport Strategy in turn:
1 A healthier Greenwich
Restricting through traffic east and west of Greenwich Park, particularly commercial vehicles, will encourage residents to walk, scoot and cycle.
Reduction of traffic flow reduces harmful emissions, including CO2, and makes the environment healthier for all residents
2 A safer Greenwich
Again, restricting through traffic east and west of Greenwich Park, will particularly benefit families with younger children on their journey to-from James Wolfe and other local schools. Short journeys to local shops will be taken on foot.
3 A cleaner, greener Greenwich
An ANPR scheme not only reduces vehicle use, but, with possible exemptions for electric vehicles, it supports the aim of encouraging cleaner cars and accelerating their take up. A further option may be to direct funds collected through violation fines to accelerate installation of EV charging points in the area.
4 Economic prosperity for all
The proposed restrictions into the ANPR-protected area would ensure access for delivery vehicles to local businesses while encouraging greater footfall of customers, especially for retailers. Exemptions can be calibrated (see evidence from London Borough of Hammersmith and Fulham.) to ensure accessibility for groups with protected characteristics.
5 A great place to be
During the operation of the West Greenwich LTN, many residents enjoyed greater interaction with their neighbours because they spent more time in the safer, quieter streets. This opportunity should be reinstated and extended east of the Park to improve the connectedness and resilience of communities.
The Greenwich Society urges decision-makers to adopt our action plan to support the objectives within the above themes:
- Install ANPR cameras restricting access through an area within (approximately) Greenwich South Street – A206, the A2 and the A102. Many streets abutting this already have traffic reduction/restriction measures in place. At least two ANPR cameras remain from the short-lived LTN, thus reducing the initial cost.
- Use existing parking permit data for issuing permission to travel across monitored points. Introduce a registration fee to permit access for residents who currently use off-street parking (whose vehicle details are not currently held by RBG parking).
- Adopt a system similar to Hammersmith and Fulham for temporary permits to be issued, eg for visitors/trade etc.
- Require residents benefitting from the scheme (in terms of safer and cleaner streets) and wishing to travel through the camera-monitored zone to pay a small additional annual fee on top of current parking permit charges.
- Where permissible, deploy revenue from fines and additional charges for further support of the strategy goals – eg construction of cycle hangars.
- Carefully consider a range of criteria for exemptions, avoiding discrimination (see Hammersmith and Fulham).
- Clearly state the exact objectives of the scheme at the outset and rigorously collect and publish traffic flow data and air quality data to monitor progress and evaluate success on a suitable timescale.
Concerns have been expressed that preventing traffic flow through specific streets might exacerbate congestion on arterial roads bounding the zone. We strongly support RBG’s efforts to work closely with Transport for London to improve availability of public transport through the Borough -particularly north-south-routes – therefore reducing private car use and resultant congestion on these arterial roads.
We trust this will be part of a London-wider reduction in vehicle use as we move towards carbon-neutral targets.
CONSULTATION ON SUPPORTING HOUSING DELIVERY AND PUBLIC SERVICE INFRASTRUCTURE
Response by Greenwich Planning Alliance*
Part 1: Supporting housing delivery through a new national permitted development right for the change of use from the Commercial, Business and Service use class to residential
There is a lack of clarity at the heart of the consultation paper. The text refers repeatedly to the proposal being aimed at high streets and town centres but in paragraph 16 it is stated that, “The Commercial, Business and Service use class applies everywhere in all cases, not just on the high street or in town centres”. If the proposed PDR is to apply everywhere it will post a threat not only to the viability of town centres and high streets but to corner shops, village shops and other sole retailers who may be the only shop in an area.
We do not agree with the proposed new PDR. Allowing class E uses to be converted to class C3 residential use without planning consent would lead to random conversions scattered across the country. This pockmark effect would reduce the attractiveness and drawing power of high streets and town centres because of dead frontages and reduced footfall.
Such a PDR would be likely to accelerate the hollowing out of high streets and town centres. Conversion of premises to residential use would offer the prospect of a quick capital gain which would tempt landlords of commercial premises and independent, owner-occupier retailers whose profitability was marginal to sell up.
We recognise that high streets and town centres are facing serious economic problems, primarily relating to retailing. Central and local government have taken a number of measures to help diversify and rejuvenate them. Reducing the extent of high streets and town centres is one of the measures to be considered but this needs to be done in a planned way, eg by reducing retail floor space in secondary shopping areas, not randomly.
A better approach, if the government is intent on introducing this PDR, would be confine it within areas of oversupply of retail and commercial space which local authorities would designate. This would enable local authorities to integrate such action with their local plan, with Neighbourhood Plans and any other actions to revitalise high street and town centres.
Q1 Size of the buildings to which the right might apply
We oppose the proposed change of use regardless of size. Any conversion of premises to housing should be thoroughly vetted through the normal process of development control. The complex issues associated with residential development cannot be subsumed in a check list for prior approval.
In the case of the conversion of larger buildings a wider range of issues about access, parking, availability of services, amenity and recreation space should come under review.
The PDR allowing offices to be converted to housing has created a significant number of dwellings with inadequate space and daylighting standards. The government has acknowledged this and added new prior approval requirements. But other relevant planning considerations remain excluded.
In the case of larger conversions requiring investment in infrastructure and services would local authorities be able to secure a financial contribution from developers via S106 agreements? We understand that they cannot in the case of the office-to-residential PDRs.
Q2.1 Do you agree that the right should not apply in areas of outstanding natural beauty, the Broads, National Parks, areas specified by the Secretary of State for the purposes of section 41(3) of the Wildlife and Countryside Act 1981, and World Heritage Sites?
Q2.3 Do you agree that, in conservation areas only, the right should allow for prior approval of the impact of the loss of ground floor use to residential?
No. Conservation areas should not be covered by the proposed PDR. They are selected by local people and their local authorities for protection and enhancement because of their special architectural and street scape qualities and historic interest. Central government should not sweep aside these arrangements but work with local authorities to find ways of repurposing those parts of conservation areas suffering from an oversupply of retail and commercial floorspace in a properly planned way.
Matters for local consideration through prior approval
Q3.1 Do you agree that in managing the impact of the proposal, the matters set out in paragraph 21 of the consultation document should be considered in a prior approval?
No. Ensuring that new housing is fit for purpose, now and for the foreseeable future, cannot be a tick-box exercise. The list of factors in paragraph 21 omits some important planning considerations such as thermal insulation, heat and power sources and the level of emissions, amount of amenity space and access to play and recreation space. There are many other issues which arise on particular cases. For example heavy industry and waste management nearby are not the only matters that should be assessed. Even light industry in the vicinity or logistics and storage facilities may generate frequent movements of lorries and other vehicles. Many of these factors cannot be covered in a definitive list because circumstances vary but they are nonetheless important. Identifying them is what planners and urban designers are trained to do. The quality of housing created under PDR is likely to be worse without this skilled input.
Q3.2 Are there any other planning matters that should be considered?
Paragraph 17 of the consultation document permits the right to change of use to part of a building but the prior approval criteria do not deal well with consideration of the other uses in that building
Q4.1-4.2. Applications for prior approval and fees
Q5. Do you have any other comments on the proposed right for the change of use from Commercial, Business and Service use class to residential?
Part 2: Supporting public service infrastructure through the planning system
Providing further flexibilities for public service infrastructure through permitted development rights
We are not in favour of extending the existing PDRs for extensions to schools and colleges, universities and hospitals and extending them to prisons and MOD buildings on the defence estate. Such building extensions can have a significant impact on the local built environment and on local communities. They can arouse strong feelings. They are best handled through the development control process.
Any extension of the existing PDR should not apply in designated areas such a SSSIs, conservation areas, World Heritage Sites or apply to any listed buildings including buildings within their curtilage.
A faster planning application process for public service developments
We do not support the proposal to shorten the public notification and consultation period for certain major public sector service infrastructure projects from 21 days to 14 days. We do not believe this would make a significant difference to the overall timetable of projects but it would seriously prejudice the position of the public. The argument that this is justified by the practice of pre-application consultation ignores the fact that such consultation is not universally satisfactory and its reach is often limited. Furthermore with a period of only 14 days to comment people away on business, on holiday or ill may miss out.
We do not agree that the period for local authority determination of this category of applications should be reduced from 14 to 10 weeks. This risks rushed and inadequate assessment and poorer decisions. Moreover a requirement to prioritise these projects over private sector development proposals, such as large housing schemes, is undesirable and at odds with the government’s housing objectives.
Part 3: Consolidation and Simplification of PDRs
No comments on this part
- 27 January 2021
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*member organisations of the Greenwich Planning Alliance
Howard Shields – Blackheath Society
Roden Richardson – Charlton Society
Sheila Keeble - East Greenwich Residents’ Association
Laurie Baker – Eltham Society
Richard Butt – Greenwich Society
Stewart Christie – Positive Plumstead Project
Deborah Boyle – Plumstead to Peninsula
Judy Smith – South Greenwich Forum
Kevin Veness – Speak Out Woolwich
Anne Robbins – Westcombe Society
Richard Buchanan – Woolwich Antiquarian Society
Elizabeth Pearcey – Greenwich Industrial History Society