Bromley Cyclists / Bromley Living Streets joint submission
In response to the Issues and Options consultation, we have compiled a submission which explains the key issues that Bromley’s Local Plan should address. These issues relate to four sections of the Local Plan consultation document: vision and objectives, housing, employment and retail, transport and public realm.
| Vision and Objectives Accessible and safe buildings and public spaces accessible for walking, cycling and wheeling for all, including children, over-65s and disabled residents |
1. What do you think are the key issues that should be reflected in the new Local Plan Vision and Objectives?
The climate crisis. This crisis will have a major impact on our future prosperity and quality of life if the borough’s infrastructures, buildings and public spaces are not climate resilient. Equally important, Bromley must contribute to the nation’s efforts to reduce emissions and reach net zero by 2050.
Enabling active travel. To build resilience to climate change, Bromley residents will need to adopt new travel habits as the government’s net zero targets require a major shift in travel mode towards walking, cycling and public transport. The London Plan targets 80% of trips by active travel or public transport modes by 2041. In turn, it is imperative that Bromley’s streets and public spaces make it safe and convenient for all residents to walk, cycle or wheel (i.e. use a wheelchair). In particular, cycling has high potential as a low-cost alternative to short vehicle trips. Yet, Bromley’s roads fail the key test: “Would you allow your 12-year-old child to cycle on these streets?”. The dangers to cyclists are reflected in the KSI figures provided in Bromley Council report ES20295, showing that cyclists account for 1% of journeys travelled and 26% of those killed or seriously injured. Safe and segregated cycle paths are crucial to ensure cycling is a genuine option for all residents.
Accessibility. This means making streets, buildings and public spaces physically accessible for all residents, from children and families to retired residents and those with disabilities or impairments. We live with the legacy of housing, streets and public spaces designed for the needs of able-bodied adults, resulting in the exclusion of, or unnecessary danger to, those travelling in wheelchairs, many retired residents, and children. Addressing these problems should be a priority consideration for new developments.
2. What do you consider to be the major challenges the Borough should address over the next 15 years?
Reducing GHG emissions. Bromley must make its fair contribution to Britain’s efforts to tackle the global climate crisis. While many factors are outside our control, we must focus on the areas where Bromley Council has budgetary control, notably transport investments, the protection of green areas, and where it can leverage investment from TfL. Investments and incentives should encourage the public to make a major shift away towards active travel, both for local trips within the borough, and longer trips to other boroughs and central London.
Air pollution: Bromley’s older population is particularly vulnerable to the health impacts of air pollution, and the few air quality monitors installed in Bromley show that air pollution persistently exceeds the WHO’s recommended guidelines, meaning that it negatively impacts public health. Actively managing all activities that generate air pollution, from construction to motor traffic, is important to reduce air pollution.
Bromley’s ageing population: making buildings, streets and public spaces age-friendly is very important to support quality of life for retired residents. Inaccessible buildings and spaces lead to social isolation, risk of injury, or excessive social costs as family and carers must do more to support older residents in their everyday life.
The transition to EVs: the requirement to phase out new petrol vehicles by 2030 will catalyse this transition. Since EVs are more expensive, many residents who currently rely on driving face the risk of being priced out of car ownership. It is essential that Bromley Council supports alternative travel modes, namely walking, cycling, and car clubs, so that residents have alternative low-cost options for local trips.
| Housing and Green Belt Protect the Green Belt and build housing near to local shops and services, to enable residents to access these easily by walking, cycling or wheeling. |
6. Where should new housebuilding be focused in the borough, in order to meet housing needs?
New housebuilding should be concentrated around existing high streets and town centres, close to amenities, public transport, shops and other public services.
9. How important is the delivery of affordable housing, and what (if any) specific affordable housing tenures should be prioritised, e.g. social rent, low cost ownership
Affordable housing, including both social rent and low cost ownership, are very important due to the severe housing affordability crisis in London.
33. Do you agree that the Green Belt and MOL should continue to be strongly protected? If not, why do you think protections should be relaxed, e.g. to facilitate new housing and employment uses, or to meet other development needs?
Yes. Green Belt and MOL protections should be maintained, not only to protect the environmental value of green spaces but also to avoid building development in areas that are poorly-connected and will give residents, or those that need to use the development, few options to travel by active travel or public transport.
| Employment and retail High quality walking and cycling routes to make high streets commercially resilient and accessible to families, retired and disabled residents. |
17. What can we do to attract businesses to locate in Bromley and help existing businesses to grow, e.g. is there a need for affordable workspace, or are there particular types of employment space that are required?
The ‘Pedestrian Pound’ report produced by Living Streets shows that making high streets safer places for active travel, and actively calming motor vehicle traffic, has major benefits for their economic vitality. Schemes to calm traffic, expand pedestrianised areas, or introduce safe, separated infrastructure for cycling dramatically improve the aesthetic values of a high street and attract local residents to spend more time there, and more money with local businesses. This research challenges the idea that increasing parking is necessary to boost retail activity and footfall.
20. What are your views on diversifying town centres to broaden their role, e.g. introducing uses such as residential and expanding cultural and night-time economy uses?
Following COVID-19, residents are shopping online more but also spending more time in their local area, where they have switched to hybrid working. These shifts create uneven impacts on town centres and high streets: those with large residential populations within easy walking distance are thriving, while those that were mainly retail destinations for residents living further afield face decline. For declining areas, footfall and economic resilience can be improved by adjusting the land use mix to include more residential development, in conjunction with measures to enhance the liveability of the town centre and minimise the potential negative impacts of retail or night-time economy activities. Details on improving the liveability of town centres are outlined in the following section.
| Transport and public realm Age-friendly and child-friendly streets and public spaces, with mandated safe crossings linking to schools and parks |
42. What do you think are the key challenges in relation to promoting sustainable transport in the borough? What could the Local Plan do to facilitate increased levels of sustainable transport use?
To facilitate higher levels of sustainable transport, improving active travel infrastructures (including pedestrian crossings, larger footpaths and pedestrianised areas, dropped kerbs, reduced pavement clutter, separated cycle lanes and safe cycling infrastructures at junctions or roundabouts) are essential to support active travel trips, and also improve access to public transport, since residents typically need to walk or cycle to their local bus stop or railway station.
Bromley’s active travel planning and investments must take due account of relevant national, London-wide and local policy documents.
Bromley must also ensure that planning decisions actively facilitate active travel and do not pre-empt or frustrate future improvements to walking, cycling and wheeling (using wheelchairs). Specifically, we reiterate two issues raised in our joint submission to the January 2023 consultation on the Bromley Town Centre Supplementary Planning Document:
– The lack of proper planning provision to improve pedestrian and cycling connections at the A21/Mason’s Hill/Westmoreland Road junction in Bromley South
– The need to consider using green spaces as part of active travel networks
43. Should the new Local Plan have a strong emphasis on the provision of high quality public realm? Are there any particular features that new or improved public realm should include?
The public realm spans from parks and green spaces to our streetscape, roads, footpaths and public buildings such as hospitals, schools and council buildings. While no one is likely to dispute that all of this should be “high-quality”, opinions will differ on how to achieve this. Like many urban areas, Bromley’s roads were not originally designed to accommodate motor vehicles, but the borough has gradually prioritised motorised traffic over the past 70 years. To reverse this shift, which has made our streets more polluted and less safe, we suggest a set of principles that should be followed, to deliver a genuinely sustainable public realm:
– Public realm should be designed to prioritise access for sustainable modes, including by foot, cycle or public transport, as well as reducing the barriers for those with disability. An example from a local park (located in a neighbouring borough but used by many Bromley residents), the variable charges for parking in Beckenham Place Park incentivise sustainable travel by requiring drivers to factor in the negative external costs imposed by vehicles depending on the amount of pollution they generate.
– Public realm should be accessible to all, and its use by historically under-represented groups should be encouraged. Proper consideration should be given to the needs of the disabled and older people, who often face insurmountable barriers to accessing such spaces.
– Where possible, existing and new public realm upgrades should incorporate green space and natural features. For new public realm, the presumption should be that such features form an integral part of the space. This can be as simple as window boxes and planters in smaller spaces to gardens, rather than car parking in bigger buildings.
44. Is there anything else that you feel we need to address through the new Local Plan transport and public realm policies?
The lack of safe crossings linking new housing or mixed-use developments to the local street network and key shops and amenities is a significant barrier to active travel. Safe crossings should connect public spaces to people’s homes and neighbourhoods, reducing safety risks and transforming short trips from a source of danger and stress to a pleasure in itself.