Testun llawn:
Key points
The draft SPD has amended the standards for both car and cycle parking. The table below sets out the difference in standards for residential schemes. It is set out to take into account the requirement for 20% additional unallocated parking for schemes of 10 or more dwellings (and all flatted development).
As an example, a scheme of 100 dwellings (33 x1 bedroom, 33 x two bedroom and 34 x three bedroom) would require 150.5 parking spaces and 100 cycle spaces under the 2007 SPD and 200.4 parking spaces and 201 cycle spaces under the draft SPD. The draft standards do not make clear whether the parking provision should be rounded up or down to the nearest whole number, this should be explicit.
Level of parking provision required
The draft parking standards in some circumstances would significantly increase the level of parking required within development when viewed against the adopted standards. In the example set out above, the parking standards requirement increase from 150.5 spaces to 200.4 spaces (33.2% increase). The requirement will increase further as the size of the development increases. The justification for such an increase is a general increase in car ownership between 2001 and 2011 censuses which doesn't adequately take into account the spatial variation, potential change in population and any habitual changes which may have arisen. It fails to fully address the first three bullet points in paragraph 39 of the NPPF. The evidence paper is lacking in detail relating to where and how people use cars and why there is a need for such a level of unallocated spaces within major and flatted developments.
The potential significant increase in the parking requirement could have an adverse impact on high quality design and viability given the amount of space which will have to be given over to parking in any new developments and potentially expensive engineered solutions (i.e. undercroft/basements). Therefore, the issue of parking requirement needs to be less prescriptive and more flexible to allow for local circumstances; the allowances for failing to meet the standards set out in section 204 do not sufficiently allow for site-specific considerations to be taken into account. A parking survey is not a mechanism which will show, in every situation, that suggested provision is acceptable, but the draft SPD appears to use parking surveys as the only tool to allow for reduced parking provision in development.
The draft SPD is also silent on how it would be possible to provide such levels of parking within a constrained site. The design guidance suggests various ways of providing parking but does not provide advice relating to how they have arrived at these standards irrespective of public transport provision or the sustainability of the location.
Lack of Sustainable Balancing
The draft SPD also fails to consider the spatial variations of development, the impact this would have on living patterns and the impact this would have on living patterns and the impact this would have on requirement; something required by the NPPF. The standards are to be applied throughout the district which does not take into account the highly sustainable locations which are served by public transport and amenities obviating the needs for private cars (in some cases). The draft SPD should make the distinction between the sustainable urban areas within the district and allow for a reduced standard to reflect this. National policy is clear that that the planning system should encourage sustainable forms of living and increase and an increase in density in sustainable areas. Overly prescriptive, inflexible parking standards have the potential to stifle these developments. Policy TR3 also makes specific reference to the need to provide an appropriate level of parking that does not discourage efficient use of land. It further states that the levels of parking provision for new development should recognise the needs of people and reflect the differences between areas. The draft SPD currently fails to do this and should be amended. Failing this, evidence should be provided to show that the draft standards are required in all areas of the district. Warwick District has high-quality transport links via a number of main line railway stations connecting it to Birmingham and London. This means that some developments will be highly sustainable in nature and the parking standards should reflect this.
Disconnect with National and Local Policy
The NPPF is clear that the accessibility of a development and the availability to use public transport is something that should be taken into account when setting parking standards. Policy TR3 of the Local Plan is also clear that levels of parking provision should reflect differences between town centre, edge of urban and rural areas. The objective of Policy TR3 is to seek to balance these competing aims.
The draft SPD fails to take this into account as, for residential properties, there is a lack of any spatial dimension allowing for change dependant on the sustainability of the location and the type of development (i.e. a flatted development for young professionals is less likely to require parking than family homes). This should be re-considered, and the draft SPD revised to bring it in line with the relevant policy. Alternatively, evidence should be provided to show that the standards are justified throughout the district and that all types of development would require the same level of provision. Our view is that a parking survey does not capture all possibilities and a Transport Assessment may be appropriate in some circumstances; for example, where a development will require less parking provision.
In light of the above, there is a disconnect with both national and local policy. The draft SPD could also affect viability given the amount of parking that is required, the impact this will have on developable area, and the infrastructure required relating to electric vehicles.
Cycle parking/Electric vehicle charging points
The draft SPD also changes the level of cycle parking that would be required within residential developments. It also sets out requirements for electric vehicle charging points in development at 1 charging point per unit (house with dedicated parking) and one charging point per 10 space (unallocated parking). No exceptions are set out within the standards, and it is unclear what the requirement is for other forms of development that require parking (i.e. flatted developments). In line with paragraph 153 of the NPPF, we consider that these standards should be predicated on robust evidence. There is currently no evidence set out in the Draft Parking Standards Evidence Paper relating to either cycle parking or electric vehicle charging points. The electric vehicle charging requirement is set out in the Council's Air Quality Action Plan (Addendum) dated April 2014. We are also of the view that consideration of viability is needed, and linked to this, greater flexibility.
Summary
In summary the draft Parking Standards should be amended to provide clarity in how they are applied (we assume these are minimum standards). The draft Parking Standards should be more flexible and less prescriptive with requisite justification. The draft Standards fail to acknowledge local circumstances in line with national and local policy.