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Below is Bicester Bike Users’ Group response from 21 December 2020
Planning Application 20/03404/F : Symmetry Park
21 December 2020
Given the location of this development, the applicant rightly recognises that the site ought to be used for pedestrian and cycle access. However, the applicant argues that the existing provision is suitable when in fact the provision is extremely poor and non-compliant with current standards (and has been recognised by Oxfordshire County Council Highways as such). It would be unreasonable to expect pedestrians and cyclists to access the development given the current lack of provision, and the applicant should be required to provide or contribute to compliant means of pedestrian and cycle access.
To date, there has been no engagement with the local cycle organisation, Bicester Bike Users’ Group, as recommended by LTN 1/20 (10.4.17).
In its submissions, the applicant makes no reference to significant current guidance, for example Local Transport Note (‘LTN’) 1/20, the OCC Cycle Design Standards, nor the Local Walking and Cycling Plan (‘LCWIP’) for Bicester. At 4.2.2 of its Transport Statement, the applicant relies on LTN 2/08, a document originally published in 2008 and which has been withdrawn.
The applicant’s contention that the pedestrian and cycle provision is policy compliant is not supported.
2. PEDESTRIAN AND CYCLE LINKS TO THE DEVELOPMENT
LTN 1/20 requires that schemes for cycle traffic to connect to new developments will be delivered as part of those new developments (14.1.1 to 14.1.4).
The Bicester LCWIP sets ambitious targets for cycling in Bicester. Policy BCW 1 requires OCC to plan for at least a tripling of cycling and a doubling of walking trips within Bicester in the next 10 years. Policy BCW 3 requires that the walking and cycling network is prioritised in transport and road plans. Policy BCW4 requires OCC and CDC to improve the cycling and walking network by s.106 and s.278 works. The Bicester LCWIP is deemed a material planning consideration in the approval of new developments.
LTN 1/20 confirms that main roads are usually the roads where people most fear the danger from motor vehicles (4.2.5). On busy and fast roads, most people will not be prepared to cycle on the carriageway, so they will not cycle at all, or some may unlawfully use the footway (4.4.1).
On busy strategic roads where significant reduction in traffic speeds and volumes is not appropriate, dedicated and protected space for cycling must be provided (4.2.11). OCC has previously confirmed that the current speed of 50mph is due to remain, and are planning for the very high traffic volumes on this carriageway to increase. Official OCC monitoring data (site number CP303) confirms that average daily traffic flows are over 20,000 per day.
LTN 1/20 sets out the requirements for cyclists to use the carriageway. No cyclist is expected to share the carriageway with motor vehicles at any speed greater than 30mph (7.2.4). Figure 4-1 gives guidance for the appropriate provision for cyclists at various speeds. At 50 mph, the only acceptable provision is stepped cycle tracks. Any other provision is considered suitable for few people, will exclude most users, and will have safety concerns. The OCC Cycle Design Standards also require stepped cycle tracks (2.2.6 & 3.4.6).
The applicant’s submission that cyclists should use carriageways to access this proposed development (4.2.5) despite these being 50mph is therefore not in accordance with the guidance.
While it is theoretically possible to access the site by an off-road route, the route does not comply with any of the basic minimum standards for off-road pedestrian or cycle access and is effectively unusable.
At such high vehicle speeds, it is essential that there be a ‘buffer zone’ of horizontal separation between the carriageway and cycle tracks for safety and reassurance to users. At 50mph, Table 6-1 of LTN 1/20 recommends a desirable horizontal separation between the carriageway and cycle tracks of 2m, and insists on an absolute minimum of 1.5m. The OCC Cycle Design Standards require the same (3.2.7). While there is a short stretch of path on the A41 in front of the development, contrary to the requirement for segregation, this path has no horizontal separation whatsoever in the face of high traffic volumes and speeds, which is very intimidating to users.
LTN 1/20 also requires that pedestrian and cycle routes be segregated, not shared, because shared space is intimidating to vulnerable pedestrians, and discriminates against those with a disability such as the blind or partially sighted (6.5.4). The OCC Cycle Design Standards also require segregation (2.1.3 & 2.2.8). None of the paths along the A41 that could be used to access this development provide for segregation, they are all shared.
All of the relevant guidance requires a minimum width for safe and usable cycle and pedestrian facilities. LTN 1/20 requires adequate width (4.2.15). Bicester LCWIP recommends a width of 3.5m (p.21) and the OCC Cycle Design Standards insist on 2m or 1.5m at an absolute minimum (3.2.17). The current path, which for the most part is on the opposite side of the A41 to the development and requires crossing a busy and dangerous road with no recognised crossing point, is a shared pedestrian and cycle path that is generally only around 50cm (fifty centimetres) wide. The path is in a poor state of repair, and given its trivial width, is almost impossible to use, let alone share with other users, and quickly becomes overgrown with encroaching vegetation. It is not a viable route.
For these reasons, for this development to comply with the relevant policies, the applicant needs to provide or contribute to safe and viable pedestrian and cycle links consisting of segregated continuous (ie not requiring users to cross the A41) and horizontally separated paths of adequate width.
3. PEDESTRIAN AND CYCLE ACCESS
At present, access to the site by pedestrians and cyclists is envisaged to be either via a ‘green link’ path or via the main vehicular entrance. The issue with the current proposal is that it requires pedestrians and cyclists to take an unnecessarily long and circuitous route where the route from the A41 to their destination as the crow flies is in fact very short. Such a long and circuitous route is not a problem for motor vehicle users, but is a significant disincentive for pedestrians and cyclists, and will discourage visitors from using this means of access.
The OCC Cycle Design Standards require that the distance required to make a journey by bike is minimised, ideally making it more convenient to walk or cycle than drive (2.3.1). One of the basic requirements of LTN 1/20 is that of directness.
A preferable design would be to permit pedestrians and cyclists to access the development at the closest natural desire line to the approach direction. A pedestrian and cycle access point at the western corner of the development would achieve this.