Draft response by Bromley Living Streets and Bromley Cyclists

This document is our draft response to this SPD consultation written by Bromley Cyclists (part of the London Cycling Campaign – LCC) and Bromley Living Streets (part of Living Streets, the national charity for everyday walking – https://bromleyls.org.uk/), two local organisations run by and for residents of Bromley Borough. We think it is vitally important that stakeholders who care about the future of Bromley Town centre respond to this consultation because (as explained on the council’s webpage) The SPD provides detailed guidance to assist with the implementation of adopted Development Plan policies – Bromley Local Plan and the London Plan – that relate to Bromley Town Centre. We are keen to receive feedback on this draft response. We are also keen to encourage others to provide feedback.

Apart from guiding the implementation of the local plan and the London Plan, the SPD is also designed to brief developers about concerns they should take into account in formulating their planning proposals. Residents and local institutions are asked to answer by letter, by email or using an online form – see https://www.bromley.gov.uk/planning-policy/supplementary-planning-guidance. The online form is set out as 12 questions which people are requested to answer, covering the Vision for the Town Centre, the Policy Framework, the borough context, the design principles, general guidance, and more detailed guidance for eight sub-areas from the northern gateway to Bromley South.

We have considered the document mainly in terms of its provision for travel and above all active travel, i.e. walking and cycling to and from the town centre and within it. This is the second consultation Bromley Council has launched on this topic. We contributed considerable evidence to the first round in October 2020, both as individuals and as organisations. In our draft response (the document you are reading now) we have decided to set out our key ideas and concerns in relation to the document as a whole rather than focus on the 12 questions asked by the Council, to ensure a more holistic approach. The first section of our document sets out our ideas around active travel (walking and cycling as a mode of transport), the second section sets our ideas around the need for more joined-up thinking about the future of Bromley Town, and the third section zooms in to focus on two key points in the document (Site 30 at Bromley South and active travel in green spaces).

Before launching into these key sections, however, we feel two overarching points need to be made. First, we believe the ideas set out in this document should be of interest to everyone because improving active travel infrastructure improves life and accessibility for all, not just those who walk or cycle. If we (and here we use this term to include both residents and their elected representatives) make it easier, safer and more enjoyable for people to walk and cycle instead of drive, more people will do so and this reduces congestion, air pollution and fossil fuel emissions, which is good for everyone. Second, we are concerned that the current draft of the SPD does not take seriously the large body of detailed comments that residents submitted in the previous round of consultation that ended in October 2020. It lists the comments in an ancillary document (available on the consultation webpage) but largely ignores them when formulating prescriptions, notably in Section 5.

In what follows we give special consideration to the needs of cyclists, particularly those who fear venturing onto the road in view of the dangers involved.  Cycling is the Cinderella among transport modes. While there already exist extensive rail and bus networks, and people can walk practically anywhere (albeit with varying degrees of comfort and safety), cycling is seriously constrained by real and perceived dangers, notably in the busy approaches to the town centres of Bromley borough. These approaches can be navigated by highly experienced cyclists, but fail when parents are asked this key question: “would you allow your 12-year-old child to cycle in these streets?”

1: Active Travel in the SPD

Our overriding finding is that the draft SPD is contradictory in the way it deals with active travel. The report on the previous consultation (in particular, paragraphs 2.17 onwards and Appendix 1) notes that transport and infrastructure was the topic most comment upon (appearing in 98 out of 618 responses, see table 1 on page 2). It correctly reports the factors inhibiting access by pedestrians and cyclists, noting that consultees suggested that efforts should be focused on cyclists and walking as dominant modes of transport (para 2.17), existing infrastructure for active travel and public transport was unsafe and inadequate and needed to be prioritised and re-established (2.18). Para 2.25 notes that complete or partial pedestrianisation of the High Street was suggested, while para 2.26 mentions advocacy for walking and cycling routes to the town centre, an increase in outdoor sheltered spaces, more places to sit and meet, remove barriers and provide step-free access.

The problem is that these observations are scarcely reflected in the all-important Section 5 that contains general guidance for transport and connectivity. Box 1 below shows where SPD guidance contradicts consultation findings and well-known facts on the ground.

This leaves us with questions as to the Council’s purpose in consulting over the SPD document: is it sincerely interested in residents’ opinions? If the answer is ‘yes’ then perhaps it would be appropriate for the Council to explain to residents why important points about sustainable transport modes raised in the earlier consultation have not made it into the latest draft of the SPD guidance.

By the same token, we find that the Council is paying insufficient attention to policy documents that emphasise the importance of active travel, notably: (a) documents written before Covid, including the London Plan, the Local Plan and the Local Implementation Plan for transport (LIP3), and; (b) those issued by the central Government since the onset of Covid, such as the DFT Guidance of May 9th 2020, and the radical manifesto called Gear Change. Through these documents and its funding of Active Travel England, central government has consistently shown its determination to increase active travel. We would like to see Bromley aligning with this policy.


Para 5.21 and Figure 4 (see below) show Bromley Town Centre’s key connections and potential connections, but these fail to include connections to most of the town centre’s hinterland.  It shows the need for improvements in connectivity within the town centre itself and across Kentish Way, but fails to consider the problems faced by people approaching from places like Bromley Common, Petts Wood, Locksbottom, Hayes, Grove Park, Sundridge etc..

Para 5.22 makes the statement that Bromley Town Centre benefits from excellent accessibility via various modes of transport, particularly walking, cycling and public transport, ignoring consultation responses which show that accessibility for cyclists is very poor and also contradicting the statement in para 9.1, which we cite below, about accessibility through Bromley South. This makes the text of paragraph 5.22 appear disingenuous.

Para 5.23 does even worse when it states that at a wider scale, various London Cycle Network Routes – Routes 27, 28, 63 and 75 – connect Bromley Town Centre with other parts of the Borough and to Greenwich, Lewisham and other Boroughs in London.  None of these roads meet London Cycle Design Standards (LCDS) or the DfT LTN 1/20 standard. LCN75 includes Westmoreland Road, the junction of Westmoreland with the High Street, Masons Hill, Kentish Way and Widmore Road. Just ask yourselves, how many parents would be willing for their 12 year-old-child to ride along any of these routes? By contrast, the SPD guidance ought to state that all infrastructure shall be brought up to the above-mentioned standards or, at the very least, record in writing why Bromley Council does not believe these standards are appropriate.

There is no consideration of the possibility of further pedestrianising or providing segregated cycle lanes within the town centre, particularly the high street.

In the light of observations in Box 1, we recommend that SPD guidance:

  1. recommend provision of safe cycle routes, including segregated cycle lanes within the town centre and linking it with its hinterland, as well as better provision for pedestrians; 
  2. recommend that all cycling infrastructure be brought up to London Cycle Design Standards (LCDS) or the DfT LTN 1/20 standard, and;
  3. include the expectation that developers will commit to S106 funding for improvements to active travel.

Figure 4 from the SPD document: Bromley Town Centre key connections and potential connections

2: Joined Up Thinking for the future of Bromley Town Centre

We feel that the SPD needs revising to ensure a more holistic, joined-up vision of the future of our town centre. At present it contains a rather wordy vision statement with a set of disparate goals, a list of relevant planning/policy documents, and ideas in relation to specific locations; what the document clearly lacks is a holistic vision of the required direction of travel for the town centre.

The current draft of the SPD makes significant concessions to the status quo, notably regarding ‘heritage and conservation’. Heritage and conservation are important, but if heavily prioritised over other goals can result in missed opportunities, as happened with the leisure centre Areli has taken off the table for Orpington.[1] While we agree it is important to value and preserve beautiful buildings and vistas, we should remember that Bromley town’s transformation since the mid-19th century has left it with much less to conserve than many towns in neighbouring Kent. While we appreciate that some people object to any development proposal higher than three or four stories, it is important to acknowledge that it is necessary to increase density, for two reasons: firstly, to meet housing demand (the only alternative is building over parks or the Green Belt), and; secondly, to ensure that the footfall needed to make the town centre attractive for business based there and ensure that it is a vibrant place that people will wish to visit.

SPD guidance also needs to engage with the challenges of congestion, air pollution and climate change that threaten the planet, while making it easier for people to travel on foot or bicycle. Instead of this, the document leaves with us the impression that the Council is opposed to travel on foot or bicycle, an impression that has certainly been reinforced by Cllr Fawthrop’s recent attempt to remove the term ‘active travel’ from a key section of the Council’s draft Urban Design Guide and an email from the Portfolio Holder for Transport, Cllr Bennett, in which he refused to meet with us.[2] With reference to our comments in section 1 above, we note that ensuring active travel provision will also serve to make the area an even more attractive destination for shopping and residing, by reducing congestion and air and noise pollution and by improving accessibility.

In our view, the concept of “15 Minute Cities” is a valuable tool for thinking through the future of Bromley Town Centre as well as other town centres/high streets in London Borough of Bromley.[3] In a nutshell, it helps us think about how we can make local high streets and town centres the go-to place for people to meet their everyday needs, which is understood to have benefits for local businesses, civic life, community cohesion, as well as health and reducing fossil fuel dependency (because significantly more people find they can access what they need close by and get there on foot or by bicycle rather than using a car to travel afield). Popularised recently by Paris Mayor Anne Hidalgo and Carlos Moreno, a driving force behind the Paris city plan, there are manifestations of the 15 Minute City around the world.[4] Core principles include:

  1. Ensure easy access to basic amenities including groceries, fresh food and healthcare in every neighbourhood.
  2. Build a multicultural neighbourhood that includes different housing types and levels of affordability, with the convenience for everyone of living close to the workplace.
  3. Have abundant green spaces to ensure access for everyone to the natural environment and clean fresh air.
  4. Establish smaller-scale offices, and retail, hospitality and co-working spaces, so that more people can work closer to home or in a virtual set-up.
  5. Create walking and cycling corridors to facilitate ‘soft’ transportation and reduce the convenience of travelling by car.

As demonstrated in many towns and cities around the world, embracing these principles creates an environment where people naturally choose walking and cycling for short journeys.

There is great potential for this to happen here too. In Britain, 20% of journeys by car are under 1 mile, a distance easily walked in 15 minutes, or cycled in 5 minutes. 38% are under 2 miles, a distance easily cycled in around 10 minutes. Enabling some or most of these journeys to be walked or cycled instead will of course greatly reduce traffic volumes, and realise the many health and environmental benefits that come from quieter, safer streets.[5]

3: Two key/priority points in the SPD document

3.1: Lack of proper planning provision for Site 30 in Bromley South

This site is referred to Section 9 of the SPD document. Para 9.1 correctly says that

opportunities for improving pedestrian and cycling connections should be prioritised, both north-south connections to the rest of the town centre and improved connections to adjoining areas to the south of the town centre. Currently, the existing road layout acts as a barrier to connections from the south, particularly on Mason’s Hill at the Westmoreland Road and Kentish Way junctions. Local Plan policy 35 identifies A21/Mason’s Hill/Westmoreland Road junction capacity improvements to tackle congestion and facilitate new development. New development in the sub-area may be required to contribute to delivery of these improvements.

This is entirely in accord with the consultation responses, but does not seem to have been translated into planning provisions for Site 30, i.e. the location of the old DHSS building on the junction at 1 Westmoreland Road. Para 9.23 discusses factors bearing on the use of this site and the design of buildings to be located there but does not treat transport & connectivity as one of these factors. It is taken for granted that the property can be developed without damaging prospects for pedestrian and cycling connections prioritized in para 9.1.  Before such development is authorised, the Council should determine whether some of this land needs to be set aside for expanding the junction to allow for adequate pavements and a segregated cycling lane around the junction.

3.2: Failure to consider green spaces in active travel linkages

In talking about “Green networks” paras 3.31 to 3.33 refer to nature and biodiversity, but don’t consider how green space can contribute to the creation of an interconnected walking and cycling network. Indeed, some of Bromley’s green spaces are not open to cyclists. Being adjacent to Lewisham Borough, Bromley is at the end of the Waterlink Way, an outstanding walking and cycling route along the Pool River, starting just north of Penge and joining the Ravensbourne near Catford. It is a very inspiring green route through Lewisham borough. We feel that Bromley should be learning from such examples and looking for opportunities to develop routes through parkland and close to watercourses.  One possibility would be a route along the Ravensbourne and through Norman Park linking Keston, Hayes and Locksbottom with Bromley Town centre. 

4: Conclusion

We have argued for a substantial redraft of the SPD document to bring in more joined-up and policy-relevant thinking about Bromley’s town centre, in the hope of creating an area with enhanced footfall for shops and businesses. In planning for transport and connectivity, the Council needs to make better use of policy documentation and consultation responses already in its possession. These indicate that, contrary to what is implied in para 5.21 to 5.23, many existing connections are not fit for purpose. Moreover, the SPD document needs to consider the connectivity with the wider hinterland, instead of focusing narrowly on connectivity within the town centre – particularly as regards cycling.

End notes:

[1] We recognise there are dangers inherent in providing a simplified narrative about what happened with Areli in Orpington. Nevertheless we believe it is appropriate to point out that from a certain perspective, it appears that the developer Areli was initially willing to build a new leisure centre for Orpington as part of its proposal and the ‘leisure centre offer’ has now been withdrawn by Areli on the basis that they have been told they cannot build buildings of a sufficient height to justify the costs associated with building the leisure centre. One way of describing what has happened here is that a group of campaigners who are ‘anti’ tall buildings have succeeded in polarising the debate about the future of Orpington to such an extent that Orpington has ‘missed out’ on the opportunity to get valuable infrastructure (a leisure centre) which would probably have benefited both residents and local businesses in a manner that would have increased the viability of the high street as an attractive destination for work, shopping and social life.

[2] We emailed Cllr Bennett twice in the months following his acceptance of the title of Portfolio Holder for Transport, in each instance inviting him to a meeting to discuss how Bromley Living Streets could support his work as Portfolio Holder for Transport. He did not respond to our first email. When we wrote a second time he replied the same day. The text of his email to Bromley Living Streets, sent on 2 September 2022, read as follows: “Thank you for your invitation. Bromley Council has well formulated policies for improving air quality, moving towards zero carbon status by 2027 and for ensuring our streets are safe. Given the policies espoused by your campaign group are, in the main, not ones which Bromley Council supports, I can see no purpose in a meeting.”

[3] You can read a summary of Bromley Living Streets’ webinar “Introducing ’15 Minute Cities’” here: https://bromleyls.org.uk/uncategorized/15-minute-cities-webinar-recap/

[4] These include ‘ciudad a escala humana’ (‘human-scale city’, Buenos Aires), ‘complete neighbourhoods’ (Portland, Oregon), ‘Barrios Vitales’ (’vital neighbourhoods’, Bogotá), ’20-minute neighbourhoods’ (Melbourne) and ‘superblock’ (Barcelona).

[5] Some further reading on 15 Minute Cities can be found here: https://www.newscientist.com/article/2309343-pedestrian-friendly-cities-have-lower-rates-of-diabetes-and-obesity/; https://www.arup.com/perspectives/the-fifteen-minute-vision-future-proofing-our-cities; https://www2.deloitte.com/global/en/pages/public-sector/articles/urban-future-with-a-purpose/15-minute-city.html; https://www.bloomberg.com/news/features/2021-01-05/a-tiny-twist-on-street-design-the-one-minute-city; https://www.newscientist.com/article/2309343-pedestrian-friendly-cities-have-lower-rates-of-diabetes-and-obesity/; https://www.sustrans.org.uk/our-blog/research/all-themes/all/key-walking-and-cycling-statistics-for-the-uk; https://www.cycling-embassy.org.uk/wiki/cycling-is-not-practical-for-the-transportation-or-commuting-needs-of-most-people#:~:text=A%20significant%20percentage%20of%20these,made%20by%20car%20or%20van.

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