Introduction
We are concerned that:
- The sustainability Appraisal states that with this plan “traffic emissions are predicted to increase” (6.16.2) – this is not consistent with stated aim of securing radical reductions in carbon emissions and improving air quality.
- The plan contains no specifications or standards – compare for example the Oxford Local Plan p111 & 246) that specifies the exact quantity and quality of cycle parking that must be provided for any development, and where it must be positioned. We need to create the standards before asking for any planning proposals.
- The plan contains no indication of how the prioritisation of sustainable travel will be monitored, achieved, or measured.
- The Plan outlines a number of very specific new road projects, with promises to look at costings and find funding sources. However, not a single new active travel route is mentioned – instead there are just vague references to the “forthcoming” Local Cycling and Walking Plan.
- This plan only talks about building cycle and walking infrastructure within developments. There’s nothing about building new cycle and walking routes into the town centre.
- The blue lines on the maps are vague and confusing. On some maps the key states they represent walking routes while on others they are for both walking and cycling. They need to be for both, and to LTN1/20 standards.
- Policy TR3 talks about safeguarding land in order to deliver new roads, while sustainable transport routes only get a much vaguer “may be investigated”.
Policy N1 – Spatial Strategy for Northampton (Principal Urban Area)
Policy N1 states that the Council will support proposals which contribute to, and result in, the regeneration of Northampton, and infrastructure, particularly where they: “Deliver and / or contribute towards strategic and local transport schemes; prioritise improved pedestrian/ cycle/ wheelchair priority through and to Northampton town centre and district centres; incorporating public realm and cycle parking improvements; secure sustainable transport and access for all to and from major employers, education and research clusters, hospitals, schools and colleges; and support improvements in local air quality. Proposals must also improve connectivity whilst supporting active and safe travel.”
While this may sound positive, it’s extremely vague. For example there is no specification for “cycle parking improvements”. Oxford’s Plan includes a Cycle Parking Policy (page 246) which specifies the minimum requirements, in terms of the quality of the cycle parking, the quantity that must be provided, and where it should be positioned.
Policy N2 – Northampton, Defining the Roles of the Town Centre
Policy N2 states that proposals should “improve in a sustainable manner the connectivity, safety and legibility of these areas, including those which increase connectivity to and within the town”
To be meaningful, this needs to be much more specific and provide answers to the following:
- Where will the new LTN1/20 routes be built that will enable people to cycle safely into town with their families?
- What routes will there be to enable children to cycle to school?
- Which pavements will be prioritised for improvement so that wheelchair users can use them, instead of having to use the road?
- How will Abington Square be transformed to make people want to walk and cycle through it?
Policy N4 – Northampton Waterside Enterprise Zone
Policy N4 states that developments at Waterside should “ensure that transport connectivity and accessibility form a vital part of the development design process to include provision for public transport and cyclists. Particular attention needs to be given to improved and sustained connectivity with Northampton Town Centre, the train station, the University of Northampton and residential areas.”
The council should have a vision for what this means. It needs to state what new infrastructure needs to be built, specify the route and design and then ensure that developers contribute to the cost via Section 106 or CIL.
Policy N7 – Northampton, land allocated for employment
There is a lot of detail on new roads here – clearly the council has a clear idea of what new roads it wants, but there is no parallel plan for sustainable transport. This directly contradicts the statements about wanting to secure radical reductions in carbon emissions and prioritise walking and cycling.
Policy N8 – Northampton, land allocated for employment
The Sustainability Assessment points out that this development is not sustainable. This is not a “Sustainable Urban Extension”.
Policy N9 Northampton Neighbourhood centres
The policy states: The motor vehicle should be subordinate in importance on the street network. Opportunities for sustainable travel should be maximised to create neighbourhoods where alternative forms of transport to the private car (walking, wheeling, cycling and public transport) are prioritised. New and enhanced pedestrian and cycle and wheel connections will be expected to be provided within the scheme.
More specification is needed for this to be meaningful. For example, the specifications for cycle parking need to be spelt out. There also needs to be new cycle parking provided at all existing local groups of shops. People will not switch from driving to cycling if there’s nowhere to park their bike when they visit the local shops.
Likewise, the council’s requirements for residential cycle parking need to be specified, as they have been in Oxford’s Local Plan.
Policy N11 Cattlemarket Road
This policy needs to includes improvements for cycling. Currently there’s no mention of active travel links, which contradicts the statements about wanting to secure radical reductions in carbon emissions and prioritise walking and cycling. To adhere to the overall policy, it needs to be stated here that pedestrians and cyclists will have priority.
Policy N12 – Northampton, Greyfriars Development Area
This is an opportunity to create cycling and walking routes to the town centre and the station. It’s essential that this is done with joined-up thinking.
The blue lines on the map show pedestrian movement but there’s nothing about cycling. This is at odds with what has been said in the text just above it. Greyfirars is absolutely key to making walking and cycling feel the most natural options.
In addition, cycle routes are needed east-west through this area to provide much needed access to the town centre and the station by bike from the Kettering Road direction – no safe route currently exists here. Just outside the Greyfriars area to the east, a pedestrian and cycle link needs to be made to Overstone Road, which in turn needs improvements to link with the Racecourse. This is essential for the proposed cycle lanes in the Greyfriars development to make sense.
Likewise Greyfriars needs to be linked to Abington Square with LTN1/20 compliant walking and cycle routes.
Policy N13 – Northampton, Greyfriars Development Area
This sentence is incomplete – it doesn’t make sense as it stands: “Proposal must secure permeability within the site for walking, cycling and wheeling, and those with mobility concerns particularly to the town centre, public transport hubs and across the river.”
The plan needs to include details of where routes need to be built into the town centre, so that the developer can be required to contribute to these.
Policy N14 – Northampton Rail Station and Railfreight
If the council really wants to prioritise walking and cycling and reduce carbon emissions, this policy is inadequate. The current planning application demonstrates how developers will do everything they can to maximise profit, and they will only adhere to guidelines and policies if they are absolutely clear.
Without much stronger and detailed policies for active travel, the Council will be seen as a “soft touch” by developers, who hope to get away with plans that would be completely unacceptable anywhere else.
The current proposals will create more traffic, which will further discourage people from cycling or walking to the station. It is essential that this is addressed, given that the stated aim of the overall plan is to reduce carbon emissions, improve air quality, and encourage walking and cycling.
It is absolutely fundamental to have good active travel and bus links with our train station:
- This plan needs to state exactly how sustainable travel to the station will be made the norm, instead of the exception.
- There needs to be a plan for a safe cycling route to the station plus safe, wider, well-surfaced pavements along St Andrews Road, which currently has narrow pavements, no cycle lanes, and no pedestrian or cycle crossing by the station. This is a perfect opportunity to get contributions from the developer.
- The sentence about Spring Boroughs states on p107 “Improved and safe connectivity, including direct pedestrian routes, with the Spring Boroughs area and the town centre will need to be created.” We agree, but this also needs to include cycling.
- As in many of the policy maps, the blue lines only talk about pedestrian movement – this is inconsistent with the text, which includes cyclists.
- Improvements for pedestrians and cyclists needs to be included on the map on St Andrew Road, between the station and Spencer Bridge Road.
- “Junction Improvements” on the map needs to state what the improvements are, and must prioritise the junctions for pedestrians and cyclists, not just for drivers.
- The shared-use pavement on Black Lion Hill is inadequate. Cyclists need to be segregated from pedestrians and the scooter parking area moved. The development will lead to more pedestrians and cyclists using the site, so this is a perfect opportunity to get developer funding for these improvements.
- For more detail, see our response – and the responses form Active Travel England – to the current planning application for the station site. But the key is to have the right policies in the Local Plan.
Policy N15 – Northampton, Ransome Road
The map needs to include cycling as well as walking. Safe and pleasant walking and cycling routes into town centre need to be built. They need to be LTN1/20 standard to cater for all abilities.
Policy N16 – Northampton, Former Abington Mill Farm
To provide proper connectivity, the walking/ cycle route from Rushmere Road over the A45 needs to be made fit for purpose and LTN1/20 compliant:
- The path is not wheelchair accessible at the bridge, because of a significant step at each side of the bridge.
- The manhole on this path near Rushmere Road is significantly higher than the rest of the path, causing a hazard for people with buggies or cycles and is not compliant with wheelchair accessibility.
- The slope up to the bridge is too steep for accessibility standards.
- The path is not maintained and it is permanently overgrown at the edges, with significant encroachment.
- The surface is not amenable to anyone using a wheelchair and is difficult and unpleasant to cycle on, particularly for disabled cyclists.
Policy N17 – Northampton, Hill Farm Rise, Hunsbury Hill
This mentions the importance of connecting the development with active travel infrastructure at Mereway. However:
- Much of the cycleway along Mereway and Danes Camp Way is not maintained. Some of it is practically unusable because of overgrowth, and much of it needs resurfacing and bringing up to modern standards
- Barriers need to be removed in the Mereway and Danes Camp area that do not comply with accessibility requirements.
- There needs to be a safe cycle route from Mereway into the town centre, to LTN1/20 standards.
- If the policy is to have more people walking and cycling these routes, it’s perfectly reasonable to expect developers to make a contribution to their improvement.
Policy N18 – Northampton, Land east of Wootton Fields
This looks like a very car-centric proposal that is not compatible with the overall stated aims of the Local Plan:
- There is nothing in the plan about how residents of this development can travel into town apart from by car.
- The plan talks about local active travel routes but these are not up to standard and do not offer a viable route into town centre to to places of employment.
- The bus services to this area are insufficient.
Policy N19 – Northampton, Land west of the A43
This policy is not compatible with the overall stated aims of the Local Plan. It states that it wants developers to “Incorporate proposals to encourage cycling, walking and wheeling; taking advantage of the availability of active routes in the locality.”
However, there is no active travel route from here to the town centre, and the bus service is inadequate. This is proposal is for a car-dependent development that will increase carbon emissions and air pollution.
Policy N20 – Northampton, The Green, Great Houghton
This policy is not compatible with the overall stated aims of the Local Plan.
There’s nothing here about how residents will get into town or to the shops, other than by car. It’s also notable that it states the SANG must have a car park, but there’s nothing about cycle parking. This is a car dependent development that is not sustainable.
Policy N21 – Northampton, Martin’s Yard extension
There is nothing about how this employment area would be accessible by bike.
Note on Travel Plans
14.2.7 states: “To achieve the above priorities this Plan supports the provision of infrastructure that will help achieve Net Zero by 2030….New developments will be connected and will need to prioritise foot, cycle and public transport modes before the individual car where possible; developments will need to demonstrate how people will travel sustainably through a detailed Travel Plan for the development.”
This statement sounds positive. However, Travel Plans are already required for new developments, yet this achieves nothing if the development is designed to fit in with active travel infrastructure.
For example, current and recent developments near Bradlaugh Fields have submitted travel plans, but although they are right next to cycleways that go to supermarkets, Moulton Park employment area, and schools, these have been fenced off. Instead, residents are encouraged to drive, as the only convenient way out of the development is by road.
This is the exact opposite of the DfT’s policy of making cycling and walking “the natural first choice”
Policy BN12
There’s nothing here that says that new trees need to be planted. We need to have detailed requirements on the number of new trees that must be planted for every dwelling built.