Application no: 20140199

Location: Cyclopark, The Tollgate Watling Street Gravesend

Description: Use of existing car park for commuter car parking. Upgrading of footpath to the existing bus stop.

Applicant: The Kings Ferry Ltd

Decision Level: Regulatory Board 28 May 2014

Recommendation: TEMPORARY PERMISSION subject to conditions

1. Description of the Site and Surroundings

The Cyclopark is located on land just beyond the southern edge of the urban area and previously this was part of the line of the old A2 prior to the re-routing of the A2 to the south of the site in 2008. It forms the central core to a wider activity park with footpaths and cycle ways running from Pepper Hill in the west to Marling Cross in the east.

The wider Cyclopark site is approximately 46 ha (114 acres) and the central core activity park accommodates the main pavilion building incorporating a café, bike rental/repair, changing facilities, etc. The remainder of the core site is occupied by the grounds which are predominantly in the form of cycle tracks, play grounds, and parking facilities.

The car park at the Cyclopark has an existing capacity of 337 cars (170 spaces within the main car park plus an overspill car park of 167 spaces), together with space for 18 motorcycles, and 80 cycle spaces. There is also coach parking facilities in laybys next to the main car park.

There are existing lighting, CCTV and Automated Number Plate Recognition (ANPR) facilities on the site. The main car park is of a tarmac finish and is marked out with parking bays and traffic management directions. The car park is secure and can be locked out of operational hours. The current parking charges are £1 all day.

The overspill car parking area is located to the south of the main car park accessed separately off the access road into the site and this also serves as a maintenance yard and compound.

The Cyclopark has a dedicated entrance / exit onto the Wrotham Road on what was the former coast bound slip road onto the old A2 and which serves also as an access to a number of residential properties in Wrotham Road and to the Tollgate petrol station (BP garage) which remains in use. This road feeds on to the Wrotham Road (A227)/Coldharbour Road roundabout.

A footpath runs parallel to the Cyclopark access road on its north side linking in an easterly direction the park with the Wrotham Road at a point just to the north of the old A2 bridge crossing and to the south of the Wrotham Road/Coldharbour Road roundabout junction and where there is a bus stop and shelter on the western side of the Wrotham Road. The footpath (part of the line of the former NG20 public footpath) links into the Cyclopark just to the east of the car parking area. It is not lit and is poorly maintained. It also adjoins a more recent footpath (which is wide, has lighting and a tarmac surface) that was constructed as a pedestrian/cycle access alongside the Toby Carvery linking Coldharbour Road with the Cyclopark in a north south direction.

2. Planning History

20090440 Application under Regulation 3 No objection 21.07.2010 for the A2 Activity Park scheme consisting of an outdoor Activity Park including car parking, pavilion and associated buildings, cycle tracks, footpaths, boundary treatments and landscaping on the A2 corridor and adjacent agricultural land. KCC GRANTED PERMISSION 16.9.10 (CONDITIONS)

20100463 Application under Regulation 3 No objection 24.06.2010 for the proposed external lighting of the core activity park, including the tarmac cycle track, BMX race track, multi- use games area (MUGA) and skate park. KCC GRANTED PERMISSION 10.9.10 (CONDITIONS)

20100464 Application under Regulation 3 No objection 24.06.2010 for the clarification of the usage of the Activity Park with particular reference to major events. KCC GRANTED PERMISSION 10.9.10 (CONDITIONS)

20121034 Display of 10 non-illuminated Refused 28.01.2013 banner signs attached to existing lamp posts.

20131036 Use of existing car park as a Withdrawn 04.03.2014 park and ride facility

3. Proposal

This application is for the use of part of the existing customer car park at the Cyclopark as a park and ride facility for commuters using the Kings Ferry coach commuting service in North Kent into London.

The proposal is for the eastern most part of the car park to be used by commuters with up to 100 spaces for the primary purpose of commuter parking (including 3 disabled bays). The operational window for commuter parking in the morning will be 6.00 – 8.00am Monday to Friday.

These spaces will be reserved up until the last service leaves ensuring all morning commuters are able to park, and that if the residual Cyclopark spaces become full they remain open to non-commuters.

It is not proposed that commuter coaches will enter or exit the site.

It is stated that Kings Ferry already operates services in the area using the existing bus stop at Tollgate. Only the bus stop nearest the Cyclopark will be used (left of roadside as heading north) to pick up and drop off, and that this is achievable via the use of the roundabout a short distance to the north for coaches to turn round to gain access again to the A2.

It is indicated that the Kings Ferry will be increasing the frequency of services at this stop from currently 12 services a day (Monday to Friday) to 22.

It is stated that the vast majority of commuters who use Kings Ferry coach services are regular commuters who use season ticket passes to board. It is proposed that these commuters also have a ‘parking permit’ with their number plates on a database, recognised by Cyclopark’s Automated Number Plate Recognition (ANPR). This will allow commuters to park all day without incurring a parking charge for overstaying the permitted 3 hour limit.

It is proposed to improve the footpath that connects the car park with the Wrotham Road; the path will be trimmed back with lighting implemented and a new surface laid.

The application is accompanied by:

A Planning Statement Transport Note Air Quality Assessment Noise and Vibration Assessment

The applicant states in the Planning Statement that:

Cyclopark has a large amount of parking, they have rarely reached saturation point. Indeed on only 3 occasions has Cyclopark exceeded its car parking capacity. Fortunately, the site has an overflow parking facility with a further 167 parking spaces available if necessary. Special events such as this are firstly, rare and secondly, usually held on weekends and evenings.

4. Development Plan Policy

Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires applications to be determined in accordance with the development plan unless material considerations indicate otherwise. Where there are other material considerations, the development plan should be the starting point, and other material considerations should be taken into account in reaching a decision. One such consideration will be whether the plan policies are relevant and up to date.

The 2004 Act provides that if there is a conflict between policies, the most recent policy will take precedence. Local planning authorities need to decide what weight should be attached to a particular material consideration, e.g. the weight to be attached to policies in emerging Development Plan Documents depends upon the stage of preparation or review.

The Regional Strategy for the South East (the South East Plan) has now been partially revoked following an Order the Secretary of State laid before Parliament which came into force on 25 March 2013.

The written ministerial statement is clear that from 25 March 2013, development plans across the former South East government office region will comprise local plans, and where they exist, neighbourhood plans. Central Government believes that this will enable councils to make the development choices that work for them; choices that are right for their communities and respond to the needs of the local area rather than to arbitrary top-down targets.

The Development Plan for Gravesham therefore comprises:-

• Saved Policies of the Gravesham Local Plan First Review (1994) • Saved Policies from the Kent Minerals and Waste Local Plans.

There are a number of other un-adopted planning documents (e.g. The Gravesham Local Plan Second Review) which are of some relevance and are a material consideration, together with national planning advice and guidance in the National Planning Policy Framework (NPPF), the National Planning Practice Guidance (NPPG), supplementary planning guidance and the emerging policies in the Local Development Framework (Local Plan).

Local Planning Guidance

Gravesham Local Plan First Review (1994)

The Gravesham Local Plan First Review was adopted in November 1994.

The Gravesham Local Plan still remains as the adopted local planning document and the written statement and proposals map will continue to have effect as the development plan pending the preparation of the Local Development Framework (LDF). A substantial number of policies of the Gravesham Local Plan First Review have been saved by a Direction dated 25 September 2007 of the Secretary of State under paragraph 1 (3) of Schedule 8 to the Planning and Compulsory Purchase Act 2004.

In the Gravesham Local Plan First Review Proposals Map the site is shown as being partly trunk road (policy T13) and partly as Green Belt (policy GB2) and an Area of Special Significance for Agriculture (Policy C1).

Wrotham Road is a primary distributor in the highway network.

Policies relevant to the consideration of this application are:

Policy GB1: Green Belt Definition Policy GB2: Development in the Green Belt Policy C1: Areas of Special Significance for Agriculture Policy T13: M2 widening and A2 improvements Policy LT1: General Leisure Provision Policy TC0: General Townscape, Conservation and Design Policy TC1: Design of New Developments Policy T0: General Transport Policy T1: Impact of Development on the Highway Network Policy T2: Channelling of traffic on to the Primary and District Distributor Network Policy T3: Development not well related to the Primary and District Distributor Network Policy T4: Development outside the Built-Up Area Policy T5: New Accesses onto Highway Network Policy T12: Facilities Relating to the A2 Trunk Road Policy T10: Public Transport Policy P3: Vehicle Parking Standards

Gravesham Local Plan Second Review Draft Deposit Version 2000

The draft Gravesham Local Plan Second Review Deposit Version 2000 (Draft Local Plan Second Review) has been adopted by the Borough Council for development control purposes but in view of the provisions of the Planning and Compulsory Purchase Act 2004, and the decision by the Borough Council to replace the Local Plan with the Local Development Framework (Local Plan) it is not being progressed any further.

The policies in the plan are therefore of only limited weight but the weight which can be attached to its policies is greater where the policies are consistent with the National Planning Policy Framework and with policies of the adopted Local Plan First Review.

In the Local Plan Second Review the site is shown as a Primary Distributor Route (Policies T1, T3, T11, and T12), Land Safeguarded for A2/M2 widening (Policy T10), and Green Belt (Policies RA1 and RA2). Other general design, transport and parking policies of the plan apply.

Gravesham Local Development Framework (Local Plan)

The Council has been in the process of preparing a Local Development Framework (LDF) for the Borough since 2005.

A draft Core Strategy and Development Management Policies Development Plan Document (Regulation 25 document – Issues and Options) was considered by the Council’s Cabinet in December 2009 who approved the document for the purposes of public consultation. A six week consultation period was undertaken between 28 January and 11 March 2010 to enable residents, local businesses and stakeholders to have their say in the future planning for the Borough.

Additional interim regulation 25 consultation was agreed to be carried out during October-December 2011 following a report to the Council’s Cabinet on 12 September 2011 as a result of changes to the planning system including the then assumed revocation of the South East Plan.

A submission version of the Gravesham Local Plan Core Strategy was considered by the Council’s Cabinet on 12 November 2012. The Cabinet resolved to publish the proposed submission version of the Core Strategy on 18 December 2012 and representations invited until 12 February 2013.

As set out in paragraph 216 of the National Planning Policy Framework (NPPF), the weight that can be afforded to relevant policies in emerging plans varies according to the stage in the preparation of the emerging plan, the extent to which there are unresolved objections to relevant polices and the degree of consistency of the relevant policies in the emerging plan to the policies in the NPPF.

The Council submitted the Submission Gravesham Local Plan Core Strategy on 22 May 2013, the Pre-hearing Meeting was on 24 July and the hearing sessions took place from 10-18 September.

Following the hearing sessions in September the appointed Inspector had advised the Council that there were concerns about the Plan’s soundness in relation to proposed total new housing provision and the annual delivery rate of housing over the plan period. Main modifications to the plan have been published by the Borough Council and further public consultation has been carried out between 4 December and 15 January 2014. Further hearing sessions took place on 8 and 9 April 2014 and the Inspectors report is expected in July.

The most relevant policies from the Core Strategy - Proposed Submission Version in relation to this development are as follows:

Core Strategy Policy CS01: Sustainable Development Core Strategy Policy CS02: Scale and Distribution of Development Core Strategy Policy CS11: Transport Core Strategy Policy CS12: Green Infrastructure Core Strategy Policy CS13: Green Space, Sport and Recreation Core Strategy Policy CS19: Development and Design Principles

A Site Allocations and Development Management Policies Development Plan Document will be prepared following the adoption of the Core Strategy.

National Planning Policy Guidance

The National Planning Policy Framework (NPPF)

The National Planning Policy Framework (NPPF), March 2012, has replaced all the national planning policy guidance (PPG’s) and statements (PPS’s) and is a material consideration.

The NPPF includes a set of 12 core land-use planning principles underpinning plan making and decision taking.

The core principles of relevance to this development include supporting sustainable economic development to meet the housing, business and other development needs of an area, securing high quality design and a good standard of amenity for existing and future occupants of land and buildings; taking account of the different roles and character of different areas, promoting the vitality of our main urban areas and protecting the Green Belts; support the transition to a low carbon future; supporting the transition to a low carbon future; and actively managing patterns of growth to make the fullest use of public transport, walking and cycling and focusing significant development in sustainable locations.

At the heart of the NPPF is a presumption in favour of sustainable development which means approving development proposals that accord with the development plan and where the development plan is absent, silent or relevant policies are out of date planning permission should be granted unless any adverse impacts would so significantly and demonstrably outweigh the benefits or specific policies in the NPPF indicate development should be restricted.

Paragraphs 203-206 of the NPPF contain advice on planning conditions and obligations.

The National Planning Practice Guidance (NPPG)

On the 6 th of March 2014 a new web-based resource for Planning Practice Guidance was launched ( http://planningguidance.planningportal.gov.uk/ ). It supports and clarifies areas in the NPPF and replaces a substantial list of guidance documents published from 1978-2013.

The NPPG includes more detailed advice on the use of planning conditions (replacing the cancelled Circular 11/95), including the “six tests”.

It indicates that when used properly, conditions can enhance the quality of development and enable development proposals to proceed where it would otherwise have been necessary to refuse planning permission, by mitigating the adverse effects of the development. The objectives of planning are best served when the power to attach conditions to a planning permission is exercised in a way that is clearly seen to be fair, reasonable and practicable. It is important to ensure that conditions are tailored to tackle specific problems, rather than standardised or used to impose broad unnecessary controls.

In respect of temporary conditions it indicates that a condition limiting use to a temporary period only where the proposed development complies with the development plan, or where material considerations indicate otherwise that planning permission should be granted, will rarely pass the test of necessity.

Conversely it indicates that,

Circumstances where a temporary permission may be appropriate include where a trial run is needed in order to assess the effect of the development on the area or where it is expected that the planning circumstances will change in a particular way at the end of that period.

A temporary planning permission may also be appropriate on vacant land/buildings to enable use for a temporary period prior to any longer term regeneration plans coming forward (a meanwhile use) or more generally to encourage empty property to be brought back into use. This can benefit an area by increasing activity.

Supplementary Planning Guidance

The following supplementary planning guidance documents are relevant to the determination of this application.

Kent Design Guide (SPG 5 published December 2005, adopted July 2006) Adopted Kent Vehicle Parking Standards (SPG 4 published in 2003 and adopted in 2006)

5. Reason for Report

At the request of the Chair of the Regulatory Board, Councillor Jane Cribbon

6. Consultations and Publicity

Consultations

Regulatory Services - Environmental Protection Comments

Original Comments

This application includes a noise assessment report provided by Peter Brett Associates reference: 30193 which assesses by prediction noise levels at the nearest residential property from the increased traffic activity at the site due to the commuter parking proposal. The report uses accepted predicted future traffic flows and considers the 24 hour average daily traffic flow provided by the transport department of Peter Brett and compares this with predicted future traffic flows associated with the development proposals. It concludes the differences between levels with and without the development are predicted not to exceed 0.2dB which would be imperceptible to the human ear and therefore the potential effect is regarded as negligible.

There are a number of queries/points of clarification raised.

Some previous comments made about this facility was the expectation is that, in view of the security problems at the facility near the Bean junction, some customers would relocate to Cyclopark site and the estimation is there could be 50-100 cars involved per day (some of which are already on the network), mainly arriving before 8am in the morning and leaving in the early evening.

The assessment report does not detail what the increase in traffic assumptions are for the development. This needs to be provided.

The 24 hour average daily traffic flow noise will mask the worst effect of this development. This will occur when the bulk of the cars arrive/leave over an hour or so in the morning/evening and will be most apparent at residences opposite the entrance to the facility. It is accepted this area is significantly affected by noise from the nearby trunk road but it does need to be quantified so all can be satisfied this matter has been properly considered.

The contents of the air quality assessment ref 30193 Feb 2014 have been considered. The conclusion that the impact of this application will not be significant in terms of air quality is accepted.

It is strongly recommended that any permission granted is conditioned to prevent the coaches picking up the customers from the Cyclopark car park itself without a further planning application at which time a further air quality impact assessment would need to be submitted in relation to the impact of the additional coach movements.

Further Comments

An update to the noise assessment report provided by Peter Brett Associates reference: 30193/0001 has been provided. This adds to the original assessment by considering the predicted peak time hourly effects and compares this to the predicted future traffic flows associated with the development proposals. It makes the point that predicting noise levels in this way does not comply with the methodology guidance of the noise model but shows the worst case hourly increase at nearest noise sensitive premises to be around 2dB worst case. (3dB is the lowest level at which a change in noise level can be perceived) and so the conclusion of the report remains that the potential effect of this development not significant in noise terms.

In my previous comments I queried whether the assumption that some customers would relocate to Cyclopark site from the facility near the Bean junction had been included in the traffic assumptions and therefore the noise report for the development.

The applicant responded to this query by Email to advise:

The current small scale P&R facility at Bean would be closed, if the new Cyclopark facility was approved and that the current customers would be encouraged to relocate though this facility. As such these trips already existing on the wider network to the east and west of the A227 on the A2, however at the A227 junction the majority would be new trips, as such PBA have assumed that they are all new to this local network, with the exception of the current bus services. Therefore the assumed traffic flows with the development are determined to be a worst case as they are all new to this location, but even with this as a premise, the impact is not considered material in terms of increase in flows, AQ or noise levels.

This Service is satisfied with this response and is satisfied with the conclusion of this matter that the potential effect of this development is not significant in noise terms.

Planning Policy Manager, GBC

Introduction

1. This as an updated version of the response on application GR/2013/1036 taking account of the additional information supplied in the new application. Primarily the new information consists of a Planning Statement prepared by Vail Williams and Transport Note prepared by Peter Brett Associates. It also takes account of the Vail Williams letter of 15 May 2014 addressing some issues that had been raised on the proposal and the future management of the car park.

2. The application is to use the current Cyclopark car park for commuter coach operations with pedestrian access using existing footpath/footways down to an existing bus stop (with shelter) on the A227 Wrotham Road northbound located just north of the old A2 bridge.

3. The draft a.m. timetable provides for 22 coaches to call – 12 of which do already – between 06:00 and 08:00. Evening flows would be between17:00 to 20:00, except on Fridays when there is a later service around 23:15.

4. The application form highlights that the intention is to replace the informal facility that exists at the Bean A2 junction, which incurs a significant time penalty due to the use of congested roads for relatively few passengers. The car park at Bean is informal, has no security and vehicles have been subject to vandalism and theft.

5. The car park at Tollgate is secure and managed, and already exists as do the footpath/footway links to A227. As indicated in the application the direct footpath link between the Cyclopark car park and the A227 is in need of clearance, enhancement and lighting.

Additional Information

6. The Planning Statement argues (at paragraph 2.5) ‘that the Proposals Map no longer reflects the area and its circumstances; as such the Cyclopark should be treated as within the settlement boundary’. It further (in paragraph 5.2) quotes Para 89 bullet 6 of the NPPF and repeats the assertion that the settlement boundary is no longer relevant and that the development is appropriate and Very Special Circumstances test is not deemed necessary. Para 5.6 states that policies within the current draft Core Strategy ‘are not part of the decision making process’.

7. The Transport note makes a number of points:

• Intending to boost the current service from 12 to 22 per day each way by cutting out Bean stops

• Aiming to use up to 100 spaces Monday to Friday (excluding public holidays)

• Arrivals and departures will be outside traditional peak times (8-9, 5-6)

• Current users of Bean car park (25-40) come approximately half west and half east of Tollgate

• Most users are season ticket holders or will book in advance and give number plate details

• There is adequate capacity for up to 100 additional car parking spaces

8. The subsequent letter clarifies that:

• some coaches will continue to call at Bean

• the applicants do not control the land used for car parking at Bean

• appear to be expecting others to improve the footpath down to the A227 and the bus shelter

• the hours of use conflict with the current time restrictions on car park usage for Cyclopark

Planning Policy

9. The proposal needs to be assessed in the context of the current development plan being the saved polices of the Borough of Gravesham Local Plan First Review 1994 and the National Planning Policy Framework (NPPF), March 2012. In addition the emerging Local Plan Core Strategy (LPCS) also needs to be taken into account. The LPCS has been to Public Examination and a consultation has been carried out on proposed modifications, both major and minor. The major modifications have been subject to a re-opened Public Examination in early April 2014. They primarily relate to housing numbers and a specific site so considerable weight can be attached to the rest of the LPCS.

10. The relevant Local Plan Core Strategy policies are CS11 (Transport) and CS13 (Green Space, Sport and Recreation). There is no direct impact on sport provision (see below on car parking) so the most relevant policy is CS11 which includes the statement “The Council will support proposals which improve transport provision and facilities in the Borough”. The proposal is broadly compatible with that policy.

11. The statement by the applicant that the Local Plan Core Strategy is not part of the decision making process is manifestly incorrect. The relevant policies have not been subject to serious objection and therefore given the progress of the plan through statutory process it is material to consideration of the application.

12. The statements about the urban boundary (which imply therefore the Green Belt boundary) are also incorrect. The south side of the old A2 remains the Green Belt boundary and this is not currently proposed for alteration. The boundary is a saved policy (GB1) from the Gravesham Local Plan 1st Review. The Core Strategy (CS02 – see Appendix 1 Map 1) adds a boundary for the Gravesend/Northfleet urban area, but this is co-terminus with the Green Belt boundary.

13. At its meeting on 31st March 2014 the Cabinet agreed to a timetable from preparing a Site Allocations and Development Management document, with a possible review of Policy CS02 if required. On the basis of the information currently available the process is likely to need to consider the issue of Green Belt boundaries, and may address the details of the boundaries in this area. That said the existing Green Belt boundary is the key issue to be considered for this application, not what may or may not happen in the future.

14. The area of car park covered by the application is on the old A2 and therefore lies outside the Green Belt and consequentially inside the Gravesend/Northfleet urban area boundary. Whilst the Cyclopark in its wider sense is both in and outside the Green Belt the tarmacked car park is not. Green Belt policy is therefore not directly relevant to the determination of this application. The overflow car park is covered by Green Belt, but there are no restrictions on its use when needed. The comments about settlement boundary are both incorrect and not relevant.

Comment

15. As an enhancement of existing facilities using pre-existing infrastructure this is a sustainable proposal. That said there are existing commuter coach services that pick up around the urban and rural areas, which is preferable to numbers of vehicles driving to this congested location. The two policy questions arising from the proposal are:

• Does the proposal impact in any way on the use of the Cyclopark through use of its car park or the walking and cycling links in the vicinity?

• The A2 Tollgate junction is known to be operating near capacity and this proposal will increase the number of coaches using the A2 junction, and the number of vehicles using roads in the area, and can this be accommodated?

16. On the basis of the plan submitted the proposal uses about 100 spaces in the existing car park which has 187 spaces, with a further 150 available in the overflow car park. It is mentioned by the applicant that the Cyclopark overflow car park has only been used on three occasions. Chart 1 (PBA report) shows that with a 100 spaces for commuter car parking (Monday data) it is mainly in August that demand would require the use of the overflow. Logically commuter demand would be less in August due to holidays in any case. On this evidence there is not a car parking issue – though as now there may still be an issue about use of local on-street parking to avoid paying. There are existing parking restrictions in place and these could be extended if necessary. The applicant should undertake to pay the costs should this be necessary.

17. The issue of the Tollgate junction is also related to the permission for the Tollgate Motel site (GR/2013/1018) and the allocation of land south of Coldharbour Road in the Local Plan Core Strategy (LPCS), as well as overall traffic growth in the LCPS period to 2028. Modelling work in 2013 for the LPCS has shown that the junction is close to causing a safety issue due to off-slip queues at peak times extending back to the main A2 carriageway. More detailed work is needed on the local road impacts.

18. It will be necessary to continue to examine the operation of the junction in the round and develop an appropriate improvement scheme, but obvious measures could include slip road widening, traffic signals and other traffic management issues. A potential future matter relating to this application will be the continued operation of the bus stop if the link in question needs to be widened, but this is unknown at this stage.

19. It is unknown if the users of the current Bean car park who live to the west of that site (about 20 mostly in Dartford) will divert to Tollgate as this involves travelling a significantly further distance east against the overall direction of travel. As some coaches will continue to stop there those users may well continue to use it. For those living east of Tollgate (about 20 only 2 of which live in Gravesham) it is a shorter journey, and therefore they are likely to divert. The diverted numbers are therefore low. In impact terms it is primarily a question of how many users of are new to coach commuting or divert from existing services, and how they get to Tollgate. Current usage of the bus stop appears to be on a small scale.

20. The 2011 Census has 6.6% of journey to work trips by bus, minibus and coach, and 17.7% of these travel 30-40 km, which covers central London commuter trips. As a rough scale this equates to 556 people (by way of comparison rail has 3,163 for a same distance band).

21. It is a matter for the Highways Agency and Kent Highways to take a view on the highway issues but this would not on current evidence appear to raise a major issue.

22. It is noted that the footway access from the car park to the bus stop (the most direct route) is overgrown and the use should not open until this has been cleared and lit to a satisfactory standard. It is in the interests of the applicant to offer an attractive product overall. The location of this bus stop may need to be reviewed in the longer term depending what the nature of any improvements to the overall junction may need to be.

23. No objection is raised on overall policy grounds.

Kent County Council Strategic Planning

No comments received

Economic Development, GBC

No comments received

Leisure Manager, Communities, GBC

With regards to the recent application from Kings Ferry to formalise a commuter parking scheme at Cyclopark, this department is comfortable with the proposal and has been aware of previous discussions both recently, as well as at the inception of the Cyclopark development itself.

Ways to diversify income on site to support the overall provision of leisure activities is important for sustainability in the long term for the site as a whole, especially during weekdays when the site is generally less busy.

It is assumed that the reservation of spaces for the commuter scheme will not to be to the detriment of potential large scale events, for example during the school holidays, and that these eventualities/possibilities have been considered by the Cyclopark Management.

Kent Highways

Original comments

In respect of traffic impact, the potential projected maximum vehicle flows associated with these proposals represent a very small percentage of the current background flows on the local highway network at a level no greater than existing daily fluctuation. This can be demonstrated by considering that if the demand were to be spread evenly across the scheduled number of commuter buses then, even when running at full capacity (i.e. 100 vehicles) this would represent less than 5no car arrivals per scheduled bus. Additionally, at full capacity the only measurable increase in local traffic flow occurs on the access road to the site itself and this would amount to only 100 2-way vehicle movements in any one day, the majority of which would occur off-peak. There would therefore be no justification in raising objection to this proposal on highway capacity grounds.

Furthermore, the Highways Agency have raised no objection in respect of impact upon the trunk road network which represents the most sensitive aspect of the nearby A227/A2 junction in respect of capacity constraint which further reinforces the view that the proposal generates no significant capacity impact.

With regard to on-site parking provision, the surveyed daily parking levels for Cyclopark demonstrate that the capacity exists within the existing car park to accommodate the required 100 spaces for this use without impacting upon the existing Cyclopark use provided that the commuter use does not conflict with any scheduled Cyclopark event without additional parking management.

There are however a number of issues in respect of this proposal which I would recommend require further clarification and/or the benefit of appropriate additional conditions.

These issues are as follows:

It is indicated within the Planning Statement that these proposals could generate up to 500 vehicle movements per day. However, with a maximum of 100 available spaces plus an additional 10 no. bus services (i.e. in addition to the existing 12 services running from this locality) this would appear to be incorrect as the maximum number of associated single-way movements would equate to 220 (i.e. 110 2-way movements at capacity). Clarification is therefore requested in respect of the figures stated within the planning statement.

It is indicated in both the Planning Statement and Transport Statement that the commuter arrival period will run from 6:00am through to 8:00am. However, it is further stated in the Planning Statement that services will run from the pick-up stop on the A227 until 8:30am – could this detail please be clarified.

It is indicated in the Planning Statement that the commuter return period will be from 5:30pm but it is indicated within the Transport Statement that the first returns are scheduled to arrive from 5:10pm - could this detail please be clarified.

In respect of planning conditions I would recommend the following:

Whilst it is accepted that the take up of commuter spaces is projected to be significantly less than the 100 proposed spaces, the location of, and potential additional security provided at this site compared to the site to be closed at Bean has the potential to generate a further uptake of the service. I would therefore strongly recommend that an appropriately worded condition be secured requiring an enforceable control to be placed on the remaining parking spaces within the Cyclopark car park to ensure that the number of commuter spaces is limited to a maximum of 100.

The Cyclopark site has permission in place to run a number of weekday evening events per year. Whilst it is stated within this planning submission that such events are currently not being run, and that 'provisions will be made with Kings Ferry Coaches' should any such event take place in the future, I would nevertheless strongly recommend that a condition be secured requiring the existing Travel Plan attached to the Cyclopark use to be amended to the satisfaction of both the LPA and the Highway Authority to include an appropriate management scenario for this circumstance and to reflect this proposal as a whole wherever appropriate throughout the document.

Additional Comments

Following additional information from the applicant's consultant dated 15/5/14 in respect of queries raised by the planner, I would make the following final recommendation.

As previously indicated, when tested against a worst case scenario of all 100 spaces being taken up and considered as 'new' 2-way trips on the network, the proposals do not generate an increase in traffic flow any greater than what could be observed as general daily fluctuation (i.e. less than 5% over existing movements) with most of these projected movements also occurring outside of the a.m. and p.m. peak periods.

There would therefore be no justification in raising any objection in respect of potential highway impact. However, the nature of the proposal and the points of discussion which have resulted in respect of on-going management and control of parking reinforce the need for such details to be formally set out in a parking management plan which should be linked, and form an addendum to the existing Travel Plan associated with the Cyclopark facility and I would recommend that a condition be secured requiring such a management plan to be submitted for approval by the LPA and KCC prior to the commuter car park facility coming into operation.

Furthermore, whilst it is understood and accepted that the applicant has offered to fund any necessary improvements to the foot path link from the car parking area to the existing bus stop, it is unclear how this will be implemented through any subsequent planning permission and I would therefore recommend that an appropriate condition/undertaking be secured in this respect.

Subject to these issues being satisfactorily addressed, no further issues of concern are raised.

Highways Agency

Offers no objection.

Original Comments in response to withdrawn application 20131036

The HA supports the development of park and ride facilities as a means towards more sustainable modes of transport. This proposal is for a new facility to replace an unofficial facility elsewhere. Replacing the old facility is of benefit to the HA as the local junction in that area is already under severe pressure. However we appreciate it does impact on a junction in Gravesham Borough.

Generally speaking the proposed services avoid the worst of the rush hour periods. Most services are gone by 8am in the morning and in the evening the majority of services arrive back after 6pm. Additionally the numbers of people relocating from the existing facility is small when spread over the number of services that will service the new facility. Whilst there is the possibility of attracting new users this is just as likely to reduce the numbers of trips through each junction.

KCC Public Footpaths Officer

No comments received

Crime Prevention Design Advisor, Kent Police

Original Comments in response to withdrawn application 20131036

CCTV and ANPR are already in existence, however some of the CCTV cameras maybe a little obscured by planting around the site when in leaf and as such, we recommend that planting is pruned back to improve general surveillance.

We also understand that when the Cyclopark staff leave at the end of their working day (either 19:00 or 21:00 hours) a security guard (also with cleaning responsibilities) takes over as the capable guardian until midnight, by which time, the Kings Ferry commuter cars should have left the site. Gates to the facility are locked by 21:30hrs.

Secure cycle storage is currently by use of Sheffield type cycle bars, however should the demand for further secure cycle storage increase, Cyclopark may offer internal storage within the Pavilion at a later date and with discussion with Kings Ferry. Ideally all cycle storage areas should be covered by CCTV.

We understand that it is hoped that if this planning application is successful, this will reduce the requirement for commuter parking at an unstaffed site in Bean, Dartford, which does not have the benefit of CCTV, ANPR, staff or a security guard. Our records show that the Bean site does unfortunately suffer from incidents of theft from motor vehicles along with criminal damage to vehicles.

The Cyclopark has the benefit of offering a greater sense of security for commuters leaving or returning to their vehicles during the hours of darkness, along with general security of the unattended vehicles during the working day and as such, would offer the chance to reduce crime.

With this in mind we have no objections to this application and we would fully support it.

GBC Community Safety

No comments received

GBC Parking Services

No comments received

Dartford Borough Council

Regarding the existing facility at Bean, this has operated without permission for a number of years and has been tolerated by the authority, simply because it has operated without complaints (as far as I’m aware). It is most likely lawful now given the passage of time and it is doubted that we would object to any retrospective application for such a use.

The site forms part of what we call ‘the Bean Triangle’ – a parcel of land between Watling Street and the A2 that has been a potential development site for a number of years, but, due to the site’s location in the Green Belt, we’ve not ever seen any realistic proposals come forward. It is most likely that we would factor in the lawfulness of this use into any comprehensive redevelopment of the ‘Bean Triangle’ subject to it not being abandoned.

In terms of the closure of the site, it would be a shame to see the facility go. 2 junctions exist between the Cyclopark and this site so I’m surprised that Kings Ferry wish to close this one down rather than make it more formal, unless they have plans to position a bus stop on the A2 within Dartford.

UK Power Networks

No objections

Publicity

The proposal has been advertised as development affecting a public right of way.

There have been two objections received from the 28 properties in the vicinity of the site as a result of the neighbour consultation.

The objections can be summarised as follows:

• Concern at increased volume of vehicular traffic – there will be 100 extra vehicles twice a day from 05.30 until 08.30 and then again early in the evening from 17.00 onwards.

• There has not been a decrease in traffic or noise since the A2 was moved – the Tollgate service station has remained and is open 24 hours with constant HGV lorries.

• There is now increased traffic flow from the Cyclopark especially when special events are held.

• The roundabout at Coldharbour Road is unable to cope with non-stop traffic flows particularly at peak periods.

• The car parking facility at Cyclopark is intended for the visitors who visit the park not for general parking.

• Concern at parking problems if a major event coincides with the use of the car park for park and ride.

• The yellow lines in Wrotham Road do not deter on street parking and there is often overnight parking of HGV lorries.

• There are no safety provisions or speed enforcement mechanisms on the road and increased traffic will only escalate the problems.

• There are concerns for pedestrian safety for pedestrians entering the park from the additional traffic proposed.

Two other objections were received to the previously withdrawn application from other neighbours in Wrotham Road near to the entrance to the Cyclopark expressing similar comments.

There are no letters of support

7. Service Manager (Development Management) Comments

Introduction

The Kings Ferry operates one of the UK’s largest dedicated coach commuter operations and carries over 1300 passengers a day into Canary Wharf, the City of London and through to Victoria. Their pickup catchment area extends from Swale and the through to Bexley and the A2 corridor direct into Greenwich, Blackwell Tunnel and Canary Wharf as well as central London.

There are currently three park and ride facilities along the Kings Ferry routes.

These are at Wigmore, Gillingham (130 spaces), Bluebell Hill, Rochester (260 spaces) and Bean, near Bluewater, (50-60 spaces). The facilities at Bean and Wigmore offer free parking for commuters while at Bluebell Hill there is a pay and display charge of £6 per week managed by Tonbridge and Malling Council.

The site at Bean, Dartford which has been in existence for some 20 years does not have a specific planning permission, is roughly surfaced and does not have any lighting or CCTV facilities on site and apparently suffers from vandalism and thefts. It also involves, according to the applicant, a deviation for coaches from the A2 which adds time to the journey and there is particularly a problem of congestion when Bluewater shopping centre is busy for what the applicant regards as relatively few passengers.

There are currently 12 coach services calling at Tollgate each morning (route 750 and 751) which commence at and respectively with multi stops until Meresborough, Services on the M2 up to the Tollgate and then on to Bexley (Black Prince). These services do not call at the Bean, Dartford Park and Ride, which is served by separate routes from Chatham and Gillingham (via, in some cases, the Wigmore and Bluebell Hill Park and Ride facilities).

The Tollgate pick up commences at the earliest at 0611 through to 0758 on Mondays to Fridays. In the case of Bean there are 24 Kings Ferry coach services calling there from 0547 through to 0808.

The Tollgate bus stop also serves as a regular bus stop for the Arriva bus service 306/308 from Sevenoaks to Bluewater and as an occasional coach pick up point.

A planning application was submitted late last year (20131036) by Kings Ferry coaches, similar to the current proposal, to use part of the Cyclopark car park at the Tollgate for commuter parking but the application did not become a valid submission due to the lack of supporting information on highways, noise and air quality. The proposal then was for about 40-50 car parking spaces to be available for commuters.

There are two other known coach commuter services operating in the Gravesend area in addition to the Kings Ferry coaches.

These are the Reliance travel coach commuter service from Gravesend and Higham to London that operates 10 services from 05.40 to 07.25 but these coaches do not pick up passengers at the Tollgate.

There is also Clarkes of London, which has a timetable for three services running from Vigo Village through Meopham, and does a pick at the Tollgate bus stop at 06.09, 07.09 and 07.39 before running through to various drop-off points in London terminating at Victoria.

Current Proposal and Additional Information

This current proposal is for the use of the eastern end of the surfaced Cyclopark car park to be used for commuter parking for up to 100 cars (including 3 disabled spaces) during Monday to Friday (excluding Bank/Public Holidays) which is about double what was previously being proposed in the withdrawn application submitted last year.

It is indicated that the number of parking bays made available to commuters will be restricted to ensure that the day to day requirements of the Cyclopark can continue to function without interruption. Provision of additional secure cycle racks may be considered at this end of the car park.

A range of queries relating to the content of the application including the submitted plans and what were considered as inaccuracies or inconsistencies in some of the statements in the various supporting documents were taken up with the applicants and additional information was sought in amplification of the proposals.

A comprehensive response has been received from the applicants planning agents (Vail Williams LLP) and a copy of their written response is appended to this report.

A proposed service timetable has also been provided which indicates that with the additional coaches the first pick-up from the Tollgate will commence slightly earlier than currently at 06.04 but through to 07.58 as at present.

The salient points made in the response from the applicants planning agents are:

• The application is for 100 spaces which can be delineated by a sign post or painted symbols; those spaces for commuters not taken up would be used by others using the park after 8 am. • It is expected that only 30-50 cars will utilise the site in the first instance; the residual will allow for potential increase in the customer base and expected growth. • Parking permits will limit the number of spaces; customer number plates will be recognised by the Cycloparks ANPR system. • Cyclopark Trust as tenants of KCC have agreed to undertake improvements to the footpath, funded by Kings Ferry. • In February 2014, 30 passengers on the Kings Ferry coaches used the Bean, Dartford park and ride car park. 50% of those customers travel past Tollgate on route to Bean, so that the initial uptake of Bean customers transferring to the Cyclopark and ride, if the Bean car park closes, is likely to be less than 30. • The small scale park and ride facility at Bean would be closed if the new Cyclopark facility is approved and current customers encouraged to relocate to this facility. • The trips made by customers using the park and ride facility at Bean are already on the network. • There will be 220 vehicle movements associated with the park and ride facility. • The current planning restriction on the times of operation for the Cyclopark does not hold sway for this application. • The majority of Kings Ferry coaches are 49 seat capacity; current capacity is around 70%. • Currently Kings Ferry carry 10-15 passengers from Tollgate. • Customers to the Cyclopark come and go throughout one day so that numbers of spare car parking spaces is fluid. • Kings Ferry has an informal arrangement at Bean for general upkeep and tidiness but has no control over who uses it. • Currently none of the services serving Tollgate also serve Bean. In the proposed timetable services serving Tollgate will not serve or be re-routed to Bean. • The bus stop at Tollgate is municipally owned and not exclusive to Kings Ferry; concerns about the condition of the shelter should be addressed by the Council. • Bean currently has 24 services inside a 141 minute window (1 every 6 minutes). The new time table reduces services to one every 12 minutes at Bean. • The decision to leave Bean is in order to provide a quality safe option at the Cyclopark; this could be reviewed if deemed commercially viable to retain the park and ride at Bean. • The Cyclopark has been able to cope with (and has space capacity) at large events. At a big event on Friday 11 April to Sunday 14 April the car parking usage was 640 vehicles, 742 vehicles and 745 vehicles during the whole day (7am to 9pm).

The Planning Issues

The key planning matters to consider in the assessment of this application are the principle of the development and conformity with the adopted development plan, the highway impact of the development, air quality impacts, noise and vibration impacts and sustainability issues.

A number of these matters have already been considered and evaluated by others in the various consultation responses elsewhere in this report.

The Principle of the Development

The planning permission for the Cyclopark which was granted by Kent County Council in 2010 established the principle of a major leisure facility of regional significance for outdoor sport and recreation complementing the linear park that had been created on the line of the old A2 trunk road and on what was partly on Green Belt land.

The permission included the provision of a large supporting surfaced car park for Cyclopark users and therefore the consideration of the application is not about additional or new surface car parking at the site but evaluating the use of the existing car parking provision during part of the day for a different user unrelated to the Cyclopark in policy terms (in addition to the amenity and traffic impacts).

The provision of park and ride facilities (though normally for general public use) within leisure centre car parks or other car parks related to community uses is a common feature in many towns and cities and has been supported by planning authorities and has proved popular over the last 10 to 15 years, although park and ride as a concept goes back as early as the 1960’s in the UK.

It has the benefit of reducing congestion by removing the number of trips and cars from the road network and thereby reducing congestion and resulting in modal shift by increasing usage of public transport or on to high volume transport and also reducing journey time and costs as well as aiding environmental benefits.

In terms of specifically for commuter car parking for transfer to coaches it can reduce the potential for on street parking problems of customers parking in residential streets. In the case of the Tollgate stop there has been problems of on street parking nearby and although there are parking restrictions in force there are still some opportunities for commuters catching commuter coaches to park unrestricted.

The Cyclopark car park is well located for the current Kings Ferry coach service being already within about a 5 minute walk to the pick-up point and is conveniently located close to the A2 route between the Medway towns and London.

It is not considered that there are any planning policy reasons in the adopted development plan or the national planning advice (NPPF and NPPG) to object to the development as proposed.

It is evident that the number of car parking spaces as proposed to be set aside during the morning window (6am to 8 am) of 100 spaces could be regarded as being rather over ambitious having regard to the number of customers that currently use the Kings Ferry coaches daily which are stated to be between 10 and 15 passengers.

Observations carried out recently by your officers did reveal that only 9 passengers boarded the Kings Ferry coaches on the 12 services that operated at the Tollgate on Thursday 15 May (and one passenger – a cyclist – was dropped off). There were also 3 passengers that boarded the 3 services that Clarkes of London also operate from this stop. It was observed that about half of the customers using the service were dropped off by car and about half walked to the pick-up point by other means. However the Board will note the likely intention that the currently free park and ride facility at Bean, Dartford could close and customers using that facility could also divert to the Tollgate (particularly as apparently half of the customers driving to that facility already pass the Tollgate). In addition Kings Ferry anticipates increased growth in the future and potentially some commuters could also divert from other coach commuting operators in the area.

In conclusion it is not considered that there is an objection in policy terms to the principle of the development although the specific numbers of parking spaces proposed to be used as a proportion to the current spaces available is high (58% of the normal spaces or 30% of the overall number of spaces, including overspill).

Highway Impacts

The latter point then leads into consideration of the highway impacts of the development both in terms of the potential car parking impact though the loss of available spaces for customers solely using the Cyclopark and the additional number of traffic movements generated by the development either in terms of numbers of vehicles that would need to access the site in the mornings (6am to 8am) or depart from the site when the commuter coaches return (the window being approx. 17.15 to 19.30; there is also a late night return on Friday evenings only) and the additional number of coaches proposed (an additional 10 coaches) that would be on the highway network.

It should be noted that it is not intended that the Kings Ferry coaches would pick up or drop off passengers within the Cyclopark car park although there are coaches that do enter and leave the park during the day in connection with Cyclopark events and there are coach parking spaces allocated within the car park.

Kings Ferry would accept a condition to prevent their coaches from doing so as they in any case indicate that it would not be in our interest as it would introduce too great a delay in the service.

The additional coaches would, as do the current coaches, park by the bus stop in Wrotham Road for picking up and dropping off, and then turn around on the Coldharbour Road roundabout to go back onto the A2 either London bound or coast bound slips.

The submitted transport supporting note indicated that the commuter car parking of 100 spaces could be accommodated within the existing Cyclopark car park for Monday to Friday based on average weekly demand for a period for which figures are available from June 2013 to November 2013 and that the demand for car parking for major events is at weekends and evening events although there could of course be some occurrence during school holidays when events are occurring and parking demand is high.

It could be argued that the Cyclopark Trust would not want to risk the potential of there not being sufficient car parking for its own customers. The Cyclopark Trust do not consider that the use of up to 100 spaces during weekdays would impede their daily or event operations with their highest demand at weekends and the proposal would make use of underutilised facility weekdays also creating a revenue stream for the centre.

In terms of traffic generation the applicants transport supporting note indicates the majority of traffic using the site is already on the highway network and will come from the east and west via the A2 and vehicles that access the Cyclopark car park will access and exit in the main out of the defined peaks. The traffic data review estimates that the proposal will have minimal impact on the traditional morning peak hours (0800 to 0900) and similar that the proposal would not have a material impact on the network during the traditional evening peak (1700 to 1800).

The Board is advised that the assessment of Kent Highways is that the number of vehicle movements generated would not be sufficient to raise an objection on highway capacity grounds. The daily fluctuation would be less than 5% over existing movements.

It should also be noted that the Highways Agency, the highway authority responsible for the operation of the A2 trunk road, does not raise an objection on traffic grounds.

Kent Highways however recommend that a planning condition should be imposed requiring the approval of a management plan to ensure ongoing management and control of the proposed parking spaces within the Cyclopark car park. In addition they request a condition to secure the necessary improvements to the footpath link from the car parking area to the existing bus stop.

Air Quality Impacts and Noise and Vibration Impacts

Separate reports accompany the application to assess the impact of the proposal both in air quality terms and in respect of noise and vibration impacts.

The A2 trunk Air Quality Management Area (AQMA) which was amended in 2011 to reflect the realigned route of the A2 still includes the A227 Wrotham Road where the bus stop is currently located and the Coldharbour Road junction albeit not the access into the Cyclopark or old slip road to the A2.

Whilst there are understandable concerns, as evidenced in the neighbour objections, to potential impact in air pollution the air quality assessment concludes that the proposal will generate less than 500 movements per day which is the threshold defined in Environmental Protection UK guidance within an AQMA for vehicles.

Therefore the development is unlikely to have a significant impact on local air quality.

These conclusions have been accepted by the Councils environmental health officers. It is recommended by officers that a restriction be placed on any permission to ensure that no commuter coaches enter the car park to either pick up or drop off passengers and this has been accepted by the applicants.

There are also concerns about noise and vibration impacts in the neighbour responses received. The application is also accompanied by a technical assessment of noise and vibration impacts based on nationally accepted standards. The assessment concludes that no significant increases in road traffic noise are predicted as a result of the development and no mitigation would therefore be required.

There is of course a proposed increase in the number of services to be operated at the Tollgate and clearly from observations made at the site about the number of passengers that use the Tollgate stop and the number of parking spaces being proposed to be allocated for commuter services it is clearly expected by the applicants that the number of passengers will increase (partly if the Bean park and ride closes) and through general interest in the provision of such a facility in this location.

That said it should be noted that there is still traffic using the old A2 slip road to access the existing Tollgate services which are open on a 24 hour basis.

The applicants have advised that the assumed traffic flows with the development are determined to be a worst case as they are all new to this location, but even with this as a premise, the impact is not considered material in terms of increase in flows, Air Quality or noise levels.

Conversely the current Cyclopark hours are between 0700 and 2300 in respect of the pavilion building and the associated car parking and therefore the car park could be accessed an hour earlier if the park and ride facility is approved.

It should be noted that the applicants planning consultants view that the current Cyclopark condition on hours of use does not hold sway for this application is not accepted by officers.

Again commuter coaches would not enter the site and therefore would not result in additional noise or disturbance.

In conclusion the Council’s environmental health officers accept the conclusions of the technical assessment that the development is not significant in terms of noise/vibration impacts.

Sustainability Issues

In sustainability terms the enhancement of existing commuter coach facilities by the provision of a pre-existing infrastructure facility is considered a sustainable proposal and offers a sustainable transport choice and can be supported as being in accordance with policy CS11: Transport of the Gravesham Local Plan Core Strategy.

Policy CS11 indicates, amongst other things, that the Council will support proposals which improve public transport provision and facilities in the Borough.

It has been observed that a number of passengers catching the Kings Ferry coaches at this location are already dropped off by car rather than walk to the stop so that traffic is already generated by the pick-up and drop off point.

The provision of commuter car park spaces in the existing Cyclopark parking facility would add an element of control to this and potentially lead to a reduction in on road parking, slowing/stopping of traffic movement or congestion on the A227 between the A2 and the Coldharbour road roundabout.

Conversely there are other commuter coach services that pick up passengers around the urban and rural areas which may be preferable to cars being driven to a location next to the A2 Tollgate junction which is known to be operating at or near to its capacity.

8. Conclusion

It is concluded that from the technical reports submitted with the planning application and an assessment of those reports and having regard to the various consultation responses there are no overriding reasons to reject the proposal on highway, air quality or noise grounds, although it is accepted that for local residents that currently live opposite the entrance into the Cyclopark, if the proposal are accepted, this would mean an earlier opening of the Cyclopark as a result of the commuter car parking.

It might also be argued that in transport terms it would better if coaches go through the urban area and pick up ‘locally’ rather than getting commuters to drive to the Tollgate. However this particular service is already in existence, uses the current pick up point at Tollgate, and comes from the Medway towns rather than commencing more locally and there are no highway objections either from Kent Highways of the Highways Agency.

Similarly there are no overriding objections to the principle of the development or to the proposal in planning policy terms.

The balance therefore lies in favour of granting planning permission subject to planning conditions.

The actual quantum of parking spaces that would be set aside for the commuter car parking is significant as a percentage of the current car parking capacity within the Cyclopark car park and while it has been observed that the normal daytime use for patrons of the Cyclopark and its facilities appears to be relatively low, as also evidence by the parking surveys, and that there does appear to be spare capacity, it is not entirely clear whether there will be occasions when there could be some days (such as during school holidays) when major events are staged that could require the full capacity of car parking resulting in possible conflict with other potential users.

In addition the actual current demand for commuter parking based on the levels of use either indicated by the applicants or as evidenced by officers is actually relatively low in comparison with the amount of car parking proposed to be used. The basis for the extent of car parking appears to be around the need to cater for commuters at Bean car park if that current unauthorised car park is closed or because of growth in the service due to an increase in the number of coaches stopping at the Tollgate or perhaps through diversion from other coach operators or just general growth in the demand for coach commuter services to London. Potentially there is the risk that other commuter coach operator would see the benefit of such an enhanced facility or that the Cyclopark could be used as a park and ride facility in a wider sense.

There is clearly a need to ensure that the parking spaces are properly managed to avoid any conflict with Cyclopark activities.

In order to gauge the effect of all of this together with assessing the overall impact in amenity terms it is considered that it would be appropriate to only at this stage grant a temporary planning permission, but subject to other relevant planning conditions, perhaps for not more than two years, in order to properly assess the impact of the development in parking, highway and amenity terms. Such a planning limitation would accord with national planning advice in the NPPF and NPPG.

RECOMMENDATION

It is recommended that a temporary permission be granted subject to planning conditions, the terms of which will be set out in a supplementary report