Response to Piries Place planning application

We have submitted the following response to the planning application for the old Waitrose site in Piries Place.

DC/16/2506 | Partial redevelopment, conversion and change of use of numbers 1-17 Piries Place, the former Waitrose service area for mixed uses comprising A1, A2, A3, A4, A5, C1, D2 uses, new Piries Place public realm extending to Park Place, Carfax and widening to Copnall Way | Piries Place Horsham West Sussex

Horsham District Cycle Forum have reviewed the plan submitted and compared them with requests made during the public consultation

  • The changes to create a shared use path in place of the existing contra-flow on Copnall Way diminishes the cycle provision in Horsham and creates unnecessary safety issues, so it not acceptable.
  • The proposal to force cyclists to dismount coming south from Copnall Way is impractical in operation.
  • The permitted cycling proposals need to be clearly stated as there are contradictions in the application.
  • The design around the entrance and exit to the car park needs to provide a safe route for cyclists and vehicles.
  • The cycle storage provision is insufficient, not secure and is not well positioned for access from all directions.
  • There is no separate cycle storage for staff and employees.
  • There needs to be clearly defined cycle routes across the development to give safety to pedestrians and visually impaired.
  • The changes to create a shared use path in Copnall Way and also across the development, instead of separation between modes, simply creates unnecessary conflicts, putting people walking and people cycling into conflict with one another.
  • There needs to be a cycling right-of-way created in both direction from Copnall Way to Park Place.

These reasonable issues were raised during the public consultation and the developer gave reassurances that these comments will be taken on board.  They are not reflected in this planning application and we expect the plans to the revised accordingly.

Horsham District Cycling Forum considers that these matters should be requirements in order to encourage sustainable transport to and from the premises and as part of comprehensive facilities across the Horsham District.

Copnall Way Contra-Flow

The Transport Assessment reads:

“2.10 A short section of contraflow on-carriageway cycle lane is provided adjacent to the footway from the aforementioned mini-roundabout junction, along Copnall Way as far as the northern end of North Street at which point cyclists are expected to dismount.”

The proposal appears to create a shared use Pedestrian/Cycle route around the inside of the loading bay.  This reduction in cycling provision is not acceptable, especially as it creates safety hazards when deliveries cross the route. It creates conflicts between pedestrians and cyclists and now deliveries. The proposal compromises the hard won gain of a contra-flow cycle lane on Copnall Way.  It is worse than the existing provision for both cyclists and pedestrians so Horsham should not be creating new shared-use pavements of this type. NPPF National Planning Policy Framework March 2012 requires developments to “give priority to pedestrian and cycle movements.”  This priority is being eroded, replaced instead by priority given to vehicles and unloading.

Access From Copnall Way and Through the Site

The Transport Assessment reads:

“2.37 Cycle access is proposed via Park Place and Copnall Way, again via the newly resurfaced service access, thereby allowing cycle connectivity between Park Place and Copnall Way. For cyclists approaching the site from the Copnall Way Roundabout there will be signage indicating cyclists to dismount and walk their bike past the car park entrance and onwards around to Park Place before mounting and cycling on. Cyclists approaching from Park Place will be able to cycle through the development without needing to dismount.”

This seems to say cycle is permitted only one way – East to North (Park Place to Copnall Way) but not North to East (Copnall Way to Park Place) where there is a ‘Cyclist Dismount’ sign.  This is not justified and impractical.

This “one-way only for cyclists only” contradicts the facts on the ground that half of the route North to East is car access to Piries Place car park, so cars will be able to drive in/out there but cyclists apparently must walk.

This confusion continues in  Figure 108 (page 39) of the Design and Access Statement (Proposed Cycle Routes) which shows that there is no longer a cycle route East to North from Park Place to Copnall Way.  Surely this cannot be correct, as it is contradicted in the Transport Assessment 2.37 which states “Cyclists approaching from Park Place will be able to cycle through the development without needing to dismount.”

This Figure 108 also shows that the access to the Car Park is directly across a hatched area marked “pedestrianised zone”.

The design needs to provide cycles and pedestrians each need a safe route past the exit/entrance to the car park.

When asked by Horsham District Cycle Forum during public consultation, the developer appeared content with this approach however this appears to be on Horsham District Council land.  Horsham District Cycle Forum request that the designers of the vehicle route (whether Horsham District Council, West Sussex or developers) should consult with the cycle forum – as the new West Sussex cycle strategy gives a role to the cycle forums.

Cycle storage

The location of cycle parking is very important: it should be possible to cycle right up to the parking which needs to be as close as possible to the destination. It should be in a clearly visible, overlooked location with adequate lighting and CCTV for social safety at night. Well-chosen locations that cater for people arriving from all directions will reduce the number of people parking their cycles within Pirie’s Place itself. It should be possible to provide protection against the rain.

The Transport Assessment reports “2.38 Cycle parking provision is to be made adjacent to the eastern façade of Unit 5.”

This is the only location with no indication of numbers of spaces provided. This selected area for cycle parking shown on the plan set the parking in the south east corner against the side of a bin store. This is neither covered nor overlooked nor secure. There are better locations on the site.

Unbelievably there is no cycle route directly into the storage from the North (Copnall Way) direction so requires a dismount and then a lengthy walk to reach the storage area, over 50m from the north east.

When asked during the public consultation about cycle parking, the developer accepted that the position of the cycle parking indicated was poor and could be moved to  alongside the side of the hotel building to provide a more convenient and better overlooked and lit location, needed as dining and cinema are night time activities. These need to be shown on the proposals.

Additional stands could be provided to give covered cycle parking in the SW corner of the multi storey car park by removing a small section of the low wall and along the outer SW edge of the multi storey car park.

Locations in the West (Carfax) side of Piries Place for cycle storage are also needed.

Employee cycle parking: despite promises during consultation none, other than public space, are provided. The Transport Assessment notes “It is therefore conceivable that staff employed at Piries Place as well as the occasional visitor may well choose to travel by cycle rather than private car and therefore cycle parking is proposed to be provided as part of the wider public realm enhancements.”

Absence of employee cycle storage is not acceptable. Step-free access for staff and public with enough space to manoeuvre is important – especially for people with disabilities and/or non-standard cycles.

When asked during public consultation Horsham District Cycle Forum were told there would be indoor cycle parking for employees of the hotel/cinema. These need to be shown on the proposals.

Clearly Defined Cycle Route Across the Site

This route should be from Park Place to Copnall Way, be two-way and be clearly defined for the safety of pedestrians and cyclists. A narrow carriageway with low kerb rather than a single shared surface can help both pedestrians and cyclists: there is a clearer route through for cycles and it keeps the pavement clear for vulnerable pedestrians. At busy times the number of pedestrians increases and they spill into the road so the area is effectively pedestrianised. We believe that there should be a clear separation between the effective carriageway and the pedestrian space along this route. This is especially important for the visually impaired but is also useful and reassuring for other vulnerable pedestrians including those with young children and the elderly. As well as reducing the danger posed to pedestrians by motorised vehicles including HGVs, it will prevent unnecessary conflicting movements between cycles and pedestrians.

Splayed kerb are covered in Interim Advice Note (IAN) 195 from Highways England and are proven to be very cycle-friendly yet making the environment clear for visually impaired people. http://www.standardsforhighways.co.uk/ha/standards/ians/pdfs/ian195.pdf

In order to maximise the potential of the site and ensure that any future developer meets  NPPF requirements to “give priority to pedestrian and cycle movements”, Horsham District Cycling Forum would like to see that the  creation of a cycling right-of-way is included as part of any future development plans for the area.

Horsham District Cycle Forum are seeking a continuous two-way cycling right-of-way between East St, via Park Place to Copnall Way

The Piries Place link remains a potentially important part of Horsham’s cycle network providing both access and cycle parking. It links the north of town with Piries Place itself, the Carfax, East St (for shopping and dining), Denne Rd and the southern outskirts. The link is well-suited for creating a cycle route as is wide enough, is already used by vehicles and speeds are low. It would be straightforward to improve the road layout to minimise conflicts between cyclists, vehicles accessing the car park, vehicles loading and pedestrians. It was outlined in the 2013 document Joined-Up Cycling available at:  http://www.hdcf.org.uk/wp-content/uploads/2015/06/Joined-up-cycling.pdf

This development should be the opportunity to introduce contra-flow cycling throughout the Carfax, which is currently permitted in East Street and Copnall Way, but not on the east side of the Carfax. Horsham District Cycle Forum request that contra-flow cycling be introduced beyond the North entrance to the Carfax.

Relevant Policy and Guidance – Planning policy and design guidance for cycling

It is the Government’s ambition to double cycling and NPPF requires that cycling should be prioritised

The West Sussex Transport Plan 2011-2026: “The current provision of pedestrian and cycling facilities throughout the District, and in particular within Horsham, are not sufficient to support and maintain sustainable travel. This is because much of the network is disjointed and suffers from inadequate signing, safe crossing points and poor surfacing.” and therefore means that new developments cannot rely on existing cycling infrastructure to provide the level of service required by NPPF and the WSCC Walking and Cycling Strategy.

The newly adopted West Sussex Walking and Cycling Strategy 2016 “Cycling and walking is recognised as a key part of the transport mix All new (development) and improvement / maintenance schemes will consider, and wherever possible prioritise, the needs of cyclists and walkers”.

Thank you for involving Horsham District Cycling Forum.

UPDATE 14/2/17 Philip Ayerst spoke to the Development Committee on behalf of the cycle forum

The Cycle Forum has requested several minor improvements to this scheme both at consultation and planning stage. Only a few have been taken on board by the developer.

Key issue – Route from Copnall Way to Park Place, essentially north to east.

The proposal in front of you is for this as shared space between:

  • cyclists
  • pedestrians
  • visually impaired
  • mothers with children
  • service vehicles

This is a worrying mix. Cyclists have asked for a delineated cycle route so pedestrians know where cyclists are and cyclists know where pedestrians are.

This is a safety improvement as well as building a cycle network. This section of land is council owned that is being resurfaced anyway so this is the ideal opportunity to install the route,

Please install it now, while work is taking place – not jam tomorrow. There are S.106 monies available.

So we ask you as the Development Committee make a condition that a delineated cycle route between Copnall Way and Park Place be installed as part of this development.

Please involve the Cycle forum in these plans as we have technical and practical knowledge.

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