sustainable travel…” Policy GG3 - Creating a Healthy City We strongly support the inclusion of health in the strategic Good Growth policies of the plan. In particular, the approach identified in A, B, C and D and those which embed the Healthy Streets Approach in to planning decisions. Policy GG5 - Growing a good economy G – Sustrans welcomes the plan’s explicit recognition of the role of public transport, walking and cycling infrastructure in supporting agglomeration and economic activity. At a strategic level, growing London’s economy depends on the city’s ability to move people between where they live and where they work. With finite road space, this can only be achieved by shifting travel toward more space efficient means. Similarly, at a local level the improvement infrastructure for space-efficient modes of travel can (a) improve the vibrancy of places by reducing the dominance of traffic and (b) increase the people movement capacity of a street, increasing footfall and catchment areas for local shopping parades. Policy GG6 - Increasing efficiency and resilience Sustrans welcomes the focus on a zero carbon city by 2050, through a low carbon circular economy. Active travel has a critical role to play in reducing transport emissions.
H1 B 3 – Increasing Housing Supply We welcome the requirement of boroughs to identify sites for housing delivery according to public transport capacity (a) and to capitalise on the trend of, and target for, reduced car use, by redevelopment car parks and low-density retail parks. Figure 4.3 – Proximity to Town Centres Welcome the proximity to town centres and London Underground stations by walking distance as guidance for policy H1 B Chapter 5: Social Infrastructure Specific comments Paragraph / Policy Ref Comment Suggested wording and proposed change(s) S1 E – Developing London’s social infrastructure Sustrans supports the identification of accessibility by public transport, cycling and walking in the planning and determination of social infrastructure development. 5.1.8 Strongly support the application of the Healthy Streets Approach in explaining access requirements for social infrastructure. S3 - B 2 & 4 Support the requirement for education and childcare facilities to be accessible
residential parking standards parking standards where public transport, town centres and the central activities zone are more accessible as well as the need to design in sustainable travel in Opportunity Areas. We are concerned that the proposed residential car parking maxima for Outer London PTAL 2, O – 1 are above the current average levels of car ownership in these areas and would therefore enable an increase in ownership and use against the background existing rates of ownership. T6.2 – Office Parking We welcome the approach set out in T6.2. B - We are concerned the language is too weak regarding well connected office developments and those in opportunity areas, where “office developments are encouraged to be We particularly support clauses: D - recognising the major negative impacts that would accompany more generous standards in Outer London and the requirement for suitable justification; and E – Requiring a more nuanced approach to more generous standards by boroughs than simple borough-wide, which would fail to reflect the varying accessibility, density and trip generating characteristics of areas within the borough. T6.3 – We welcome the approach to assessing existing parking provision for retail development. Assessments of similar existing public provision should take account of the charging
estimate that it accounts for less than 1% of London’s street network by length. For example, we now have 31 kilometres of segregated cycle lane for a population of approximately 8 million people. Denmark’s capital, Copenhagen, has a network of 370 kilometres of segregated cycle lane serving a quarter of London’s population – it has some of the highest cycling rates of any city in the world. There is a long way to go in improving London’s infrastructure. B – support C – we strongly support the instruction to consider planning obligations for the funding of the London-wide cycle networks, in line with the Healthy Streets Approach. While we welcome the commitment to explore land value capture mechanisms in chapter 11 (11.1.13), we believe such mechanism should play a critical role in funding transport infrastructure improvements. It is well understood that land value increases with improved transport infrastructure, particularly connections to employment centres. Comments on Table 10.2 – Cycle Parking Standards All cycle parking standards are supported unless otherwise stated in the table below. Use Class Long-stay Short-stay A1 Food retail - -
11.1.33 We welcome the Mayor’s commitment to trial a more flexible approach to trial ways of paying for roads. Chapter 12: Monitoring Paragraph / Policy Ref Comment Suggested wording and proposed change(s) Table 12.1 – Key Performance Indicators We welcome the proposed KPIs for Transport – Modal Share: Increasing mode share for walking, cycling and public transport (excluding taxis) towards the target of 80% by 2041. Health – Active Travel: Positive trend in provision of cycle parking (based on a rolling average) to support the target of all Londoners doing two ten minute periods of active travel a day by 2041. Air quality: Positive trend in approved referable development applications demonstrating that they meet at least air quality neutral standard for emissions (based on a rolling average).