Local Plan ‘Direction of Travel’ Consultation

This is the Richmond Cycling Campaign response to the council’s Local Plan:

Dear Richmond Council,

We’re writing in reply to your ‘Local Plan – Direction of Travel Consultation’, linked here: https://haveyoursay.citizenspace.com/richmondecs/local-plan-20/consult_view/

This is the group response from Richmond Cycling Campaign, the local branch of London Cycling Campaign, and it has been arrived at with feedback from members locally as well as from LCC head office.


In overall summary, we welcome both this consultation and this new plan. The increased focus on supporting non-car travel modes is welcome, as is the focus on wider sustainability issues.

However, our general ‘ask’ is that these provisions are significantly strengthened in this and later revisions: if this is a plan to be used as a baseline for the next 10-20 years, it must start from the assumption that the private car should not be designed into our borough as the right way to move around, whether it is electric or not. Rather, we should ensure that the borough emerges from this exercise with a clear, robust plan to make sure that every person, everywhere in the borough, can honestly and safely make transport decisions which are low- or no-carbon, and which feel and are safe. Every time we mention or look at transport, new developments, visitors, etc., we should ask “how can people get there without a car?”

We ask this not purely because of our general interest in walking and cycling, but because taking this approach supports a range of other crucial policy imperatives, including keeping people active, reducing borough carbon emissions, prioritisation of public transport, and maximising space available for people.

Specific Questions

What challenges do you think Richmond borough faces now and in the future?

We think the rising population in the borough will add pressure to a wide range of services. Specifically we are concerned that if the borough fails to immediately design and build sustainable transport options, we will live in an area blighted by even more congestion, along with the resulting risks of pollution, road danger, severance and inactivity.

What do you think should be our priorities in the new vision?

We believe the council should focus on sustainability, and the embedding of its new transport hierarchy in all its work. As part of London, the borough should also focus on how delivering sustainable transport options requires partnership with other authorities. (The recent Liveable Neighbourhoods bid with Kingston is a good example of this.)

In addition to our existing approaches of directing larger scale development to the borough’s town centres, and expecting the majority of development on brownfield sites, where should we direct new growth in the borough?

We can’t comment directly on site choice, but we would stress that all new developments ought to be car free. If PTAL is too low for it to be considered car-free, then the solution for this is to improve PTAL, and not to simply dedicate expensive public space to car parking and driving. The suggestion has been made of an Active Travel Availability Level a good value of which would compensate for a lower PTAL. The Stag Brewery development is an excellent example of this – there’s enough road space in the area for a development of this size only if we provide for and prioritise active travel and public transport.

Should we continue to protect our green and open spaces from inappropriate development, or are there parts of the borough that could assist in accommodating growth?

As a general principle, we must protect these spaces. However, we’d also like to see our green spaces supporting active travel appropriately, and there are clear opportunities to improve walking and cycling routes around and through our green spaces.

Responses to the Specific Sections / Areas

P9: ‘what should the borough look like in 15-20 years’ time?

In the next 20 years the borough should be a place where roads look people friendly rather than  like car parks as people drive cars for exceptional journeys, if at all. A place where people move to and think “I don’t need a car”. A place where air quality in our town centres and schools is as good as the air in our parks. A place where children actively choose to cycle to school from year 4 or 5 in primary. A place where businesses and local Government have worked together to make our borough a beacon of community, supported by removing the barriers that many main roads form. A place where deliveries are by cargo bike or other emissions-free methods, and are consolidated and organised to maximise efficiency.

P13: “What do you think? What challenges do we face?

The key challenge that is faced in anything to do with transport is the utter dependence that many people feel they have on their cars. Our challenge will be creating a culture of walking and cycling for normal trips in the face of determined opposition that does not recognise the unfair dependence on car culture and how it dominates our entire streetscape.

P14-17 talks about the climate emergency.

We welcome many of the steps proposed here, especially the sustainable urban drainage programme, which has had such beautiful results elsewhere in the country.

While transport is covered elsewhere in the paper, we think more needs to be made of it in this section. Transportation produces 1/3rd of emissions, yet is not covered in detail here. We would like to see commitments, in this context:

  1. For everyone new home and office to have safe and secure bicycle parking for all residents and visitors
  2. For every home, office or place of interest to be immediately accessible to local people by walking and cycling. This means the borough needs a dense ‘mesh’ of cyclable routes never more than 200m from each other.
  3. A requirement on all deliveries in the area to be managed by consolidation hubs, ensuring that ‘last mile’ fulfilment is never by motor transport unless specific factors make this impossible.
  4. Removal of all council subsidies for driving – whether this is parking, driving, or the wide range of other activities the council has to undertake because of the damage caused to our built environment by motor vehicles.

Additionally, we’d also like this section to either include or potentially commission research to look at the carbon benefit of the different ways of moving transport choices to walking and cycling over driving.

P22-27 local town centres

We want to support local town centres and all the things people choose to do there. However, they’re invariably places of high pollution (like Richmond’s George St.), and of high perceived danger for those walking and cycling.

However, we think any long term vision for the borough needs to put people back into the town centres, and cars at the periphery. None of our town centres should be a place to ‘drive through’, nor should their space be so dominated by provision for motor vehicles. We think successful town centres are pedestrianised where at all possible, and they support frequent, smaller shopping journeys – and the borough, as part of this strategy, should be discouraging or closing ‘out-of-town’ style shopping centres built around large car parks.

P36 (culture, open land, etc.)

We would like all considerations in this area to include how people arrive at cultural destinations. For example, on match days at Twickenham, we should have a wider strategy that prioritises those who arrive by foot, by bike and by public transport.

As a general rule, it should never be easier or more convenient to drive to our cultural destinations compared to walk/cycle/public transport options, and this should be embedded in policy.

We would like to see plans for each of our cultural destinations which consider how people arrive there, capacity, etc., with planning for safe places for bike parking, and appropriate access for those who still need a motorised vehicle (for example blue badge holders).

A possible study, which could inform a number of other policy areas, could be analysis of how much space in the borough is given to car parking, whether residential or business – it would surely be worthwhile to understand how much public land is devoted to the parking of vehicles right now, as we could then have another data set to show us the benefits gained from releasing this land to other uses.

P40 uses the phrase “well served by public transport”. We very much welcome this, but want to emphasise that it should specifically include walking and cycling access as well.

P44 – with regard to trees on our pavements, we draw the council’s attention to recent discussions on how tree roots can damage pavements and make them impassable for those using (for example) walking frames or mobility scooters or chairs.

We would like to see policy specify that pavement space will not be given to trees in this way, and that:
a) Any new development will place trees into the space usually occupied by car parking, leaving clear, unobstructed pavements.

b) A programme to reallocate car parking spaces to trees – using buildouts as appropriate – whenever trees are replaced or planted.

P48 and onwards – Need to travel / sustainable travel

We welcome the analysis and thrust of this section. In our view, there is now a much clearer understanding in the council than we have previously experienced of the importance of active and sustainable travel options.

Given the related policy frameworks, from the mayor, but also from the Government, we believe that the council needs to be more aggressive in its pursuit of mode share changes, for both environmental and public health reasons.

In this section we would like to see some more detail, and some more concrete objectives that will help to deliver sustainable travel – the elements so far do an excellent job of identifying all the different things which are needed to make these goals a reality, but we would suggest inclusion of elements like:

  • A plan to offer low traffic neighbourhoods across the borough
  • A commitment to offer cycle hangars on every road by 2026
  • Provide safe, pedestrian priority crossing points on every road in the borough (whether zebra, toucan, etc.)
  • Implementation of school streets for every school in the borough by 2025
  • Design and maintain publicly shared plans to provide everyone with a safe cycle lane within 400m of their home by 2030, and 200m by 2035
  • Create a working group with town centre businesses to set up last mile transport hubs, shared deliveries, and other identified schemes to reduce and coordinate deliveries
  • Work with ‘car club’ organisations and groups to see if there are opportunities for closer working, to speed the reduction in car ownership in the borough