Grafton Area of Major Change SPD 2017

Thank you for consulting Cambridgeshire County Council (CCC) on the draft Grafton Area of Major Change Supplementary Planning Document 2017. CCC has welcomed involvement to date and it is encouraging to see a number of positive key principles reflected in the draft.
We have identified some issues, reflected in this response. Indeed the detail of how these principles come forward is a matter for the future, and we would welcome ongoing
involvement in this regard.

CCC is broadly supportive of the vision and objectives and see the SPD as an opportunity to lock in key principles that will benefit sustainable and safe movement in and around the site. A summary of our view is provided below, followed by a commentary on specific sections of the document.

SUMMARY

Walking and Cycling
* CCC supports the principle of exploring cycle routes and pedestrian connectivity through Fitzroy Street and Burleigh Street, as well as other entrances to the Grafton Centre. Careful consideration of cycle parking will be needed to ensure enough provision is provided, whilst ensuring location of parking is convenient, but does not detract from the streetscape.

* It is important to establish the hierarchy of routes for pedestrians, cyclists and vehicles.
The removal of cycling restrictions should be carefully considered in conjunction with appropriate provision of cycle lane infrastructure and how this hierarchy can work in
harmony with pedestrian routes, especially cross-cutting from opposite sides of the
streets. Consideration should also be given to ensuring cycle speeds remain low where cycling is allowed to prevent conflicts between pedestrian users and associated safety implications.

* CCC supports the need for wayfinding, both in the short term and as the development progresses to ensure smooth and confident movements across and around the Grafton Centre area, supported by positive streetscaping and accessible routes for both the mobile and mobility impaired.

Connectivity with East Road and Newmarket Road
* CCC supports the need to work in close partnership with the Greater Cambridge Partnership (GCP) and in particular the City Access team. The connectivity of the site with East Road should be improved and support a holistic approach to a new bus interchange and improved pedestrian experience between this and the Grafton Centre site.

* The potential to reduce the width of East Road carriageway would support this aim, however the wider impact of these changes would need to be further investigated through a traffic assessment and working closely with the GCP.

Public Transport
* CCC recognises opportunities to improve the public transport interaction with the site and the opportunity for a more attractive arrival environment. Changes to the public transport arrangements should be discussed in detail with the public transport operator Stagecoach, and CCC public transport leads.

Taxi Movements
* The County Council are not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

* Given the above, consideration should be given to a more appropriate location for taxi pick up and drop off - but taxis should not be allowed in any areas that are currently pedestrianised.

Car Parking Policy
* Redevelopment of the existing deck car park in Grafton West to provide same number of spaces in a single basement level would enhance the area whilst maintaining current level of spaces. This supports better connectivity to/from the site to Newmarket Road, with a strong emphasis on creating a safer passage between these areas.

* CCC supports the need for electric charging points, and this should also be encouraged in any redevelopment of the retail/public car parks.

REVIEW OF SPD DOCUMENT

1.4 Planning policy context

"Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as an increase in cycle parking through additional managed cycle parking facility, and with no increase in car parking above current levels".

This statement implies that current short stay cycle parking levels will remain as existing and additional cycle parking will be provided through an additional managed facility. It is
important that sufficient short term cycle parking is provided close to each retail facility.
Inadequate levels or poorly located cycle parking can result in cycles being locked to street furniture or in more severe cases cyclists not calling at the retail offer in the area or choosing not to cycle. It must be demonstrated that adequate cycle parking is being provided for short term convenience shoppers within the immediate vicinity of the retail offer and long term cycle parking for the employees of the facilities and long stay shoppers.

2.2.8 - Relocating the bus stops from the current bus interchange to East Road would potentially dis-benefit public transport users travelling to/from the Grafton Area as they will need to cross East Road rather than being dropped at the entrance to the Grafton Centre. Whilst supportive of the principle of improving the public transport arrangements, this will require further discussion with the operator and CCC as to how it can be best achieved.

Cycle routes and parking
2.2.10 - The SPD should make allowances for short stay cycle parking close to retail entrances and in order to facilitate current levels and proposed demand.

2.2.16 - CCC has previously requested that the servicing assessment (referred to in this section of the SPD) was to be provided to the County Council detailing the current servicing needs of businesses within the Grafton area to provide evidence to the statement:
'It is likely the existing full extent of the service areas is no longer required by the centre and the potential for public realm improvements and areas of redevelopment should be explored'.

In developing the SPD, there have been discussions about how the servicing demand / requirements might change in future. These changes are currently new concepts that are in the process or early stages of being developed. Any changes to servicing operations will need to be evidenced and ensure that they are futureproofed, thus at this stage the County Council recommend that the service areas be retained. The County Council do not support additional servicing on street and are concerned by additional conflicts that this could result in.

2.7.4 - 'create a better frontage and pedestrian environment along East Road that is no longer dominated by traffic'
The County Council recognises that the developer identifies this as a potential opportunity to change the form of East Road, however this requires further consideration with both CCC and Greater Cambridge Partnership following the outcomes of the access study.

4.2.1 - the reinstatement of connections from Fitzroy Street to East Road is still very vague. The County Council are not supportive of the reinstatement of Fitzroy Street and Burleigh Street for motorised vehicular traffic due to safety implications for vulnerable road users.

Pedestrian and cycle connectivity
4.5.4 - The reinstatement of carriageway for use by motorised vehicles is not supported by the County Council. CCC have previously advised that the Burleigh Street and Fitzroy Street design options will need to be discussed with both the walking/ cycling officer, cycle groups and mobility groups, and that these views should be fed into the SPD process. Did these meetings take place?

Public transport
4.2.15 - The proposals for buses stopping on East Road need to be discussed in more detail with bus operators and Public Transport Officers.

The SPD includes reference to working closely with Greater Cambridge Partnership but should go on to identify extending services into the evenings to serve the Grafton Area.


Cycle parking

Cycle parking provision should be compared to anticipated demand to identify whether what is proposed is sufficient. This has not been referred to in the SPD. It is important that it is demonstrated that both the short and long stay parking are sufficient to cater for demand. It is important that short stay parking levels be comparable to existing and be sufficient when compared to demand to avoid cycles being locked to street furniture etc.

4.4.24 and 4.4.28 - The County Council is not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

During the workshops locals raised issue with servicing on street currently. With the new developments, intensification of use and potential infilling of areas, there are anticipated to be additional demand for retail and other facilities in the area resulting in additional pedestrians, cyclists and public transport users being attracted to the area and potentially conflicting with existing servicing, which could potentially be worsened through the introduction of additional servicing on street.

4.5.4 - The County Council are not supportive of the introduction of taxis on Fitzroy Street and Burleigh Street. CCC have previously suggested that use of the service areas (Burleigh Place) by taxis out of hours may be an acceptable way of allowing taxis into the area without allowing access into the pedestrianised area of Fitzroy Street and Burleigh Street. However, this doesn't appear to have been carried through into the SPD.

CCC HIGHWAYS COMMENTS Planning policy context
1.4 "Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as a managed cycle parking facility, and with no increase in car parking above current levels";
* How will this be achieved by removal of the current, convenient on-street cycle parking just outside the shops and reintroduction of conflict with motor vehicles on
Fitzroy Street and Burleigh Street?

"Improve the public realm along Fitzroy Street and Burleigh Street, by removing unnecessary
signage and street furniture, and using a simple and durable palette of materials";
* How will this be achieved if more traffic regulation and enforcement would be required?
* How will this be maintained in the long term, given current financial constraints?

Parking
2.2.4 - The site is within a Controlled Parking Zone (CPZ) which means on street parking is restricted at certain times of day.
* The area is also subject to a Residents' Parking Scheme. Residents of any
subsequent development would not be eligible for Residents' Permits.

Cycle routes and parking
2.2.12 - The location and amount of cycle parking will need to be carefully reviewed as part of this SPD.
* This statement should include the stated intention that this must be as, or more, convenient to use than that which currently exists.

2.7.5 - Movement and access: Adapt and redevelop the service areas to the Grafton
Shopping centre to better integrate the shopping centre into its context.
* Should this not also include the aspiration to provide effective, efficient servicing?

Review the car parking requirement and redevelop the Grafton West Car Park.
* Surely the redevelopment should be a provisional aspiration if demonstrated to be appropriate?

4.2.18 Longer-term proposals for servicing assume that normal retail and leisure units could be serviced from key primary streets based on an agreed management strategy including core servicing hours and restrictions on maximum sizes of vehicle as appropriate.
* The reintroduction of motor vehicles, or increased servicing utilising Fitzroy Street or
Burleigh Street is seen as a retrograde step. These streets were pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Surely the aspiration should be to remove the conflict between pedestrians, cyclists and servicing vehicles, rather than manage an increased amount?

Car parking - residential and office uses
4.2.24 Cambridge City Council's car parking standards are expressed as maximum
standards in line with national guidance
* This is no longer National Guidance - please refer to the NPPF
* Residents will not have access to Residents' Permits (see above)

4.2.24 Subject to further discussion and liaison with the County Council, there is an aspiration to create an integrated approach to movement on Fitzroy Street and Burleigh Street. This could involve improved management of servicing where this occurs on street, potential for the introduction of out of hours taxi operation, cycling and other streetscape improvements.
* Servicing activity on Fitzroy Street would take place out of hours and would require enforcement, potentially utilising ANPR cameras.
* Provision for a contraflow cycle lane on Fitzroy Street to accommodate cyclists throughout the day (24/7, not restricted access as currently) is also key.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Figure 41 shows a pedestrian crossing in the junction of Burleigh Street with East
Road. If Burleigh Street is open to vehicular traffic, this is undeliverable on several levels, not least of which is highway safety.
* Provision of a segregated cycleway in the pedestrian area is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space reserved for their use.

4.5.3 Subject to further assessment, proposals should demonstrate an integrated approach to cyclist and pedestrian movement including the creation of defined footways and shared surfaces. The pavements should accommodate primary pedestrian movements and accommodate other functions such as al-fresco eating and occasional market stalls. The re- instated carriageways could have the character of a shared surface, enabling informal negotiation between users including pedestrians and cyclists.

* How do you have both footways and shared surfaces? A scheme can either be shared surface/space or segregated, not both.

* Provision of segregation in what is now a pedestrianised is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space

reserved for their use. Pedestrians will be expected to keep to the footways as identified. This downgrades the position of the pedestrian within the user hierarchy as defined in Manual for Streets, in an area where place should be dominant over transport function.

4.5.4 It is proposed, subject to more detailed design and assessment that taxis could operate on Fitzroy Street and Burleigh Street outside of core hours. The delivery of these public realm improvements should be linked to the adjacent development proposals.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.

* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.

Thank you for consulting Cambridgeshire County Council (CCC) on the draft Grafton Area of Major Change Supplementary Planning Document 2017. CCC has welcomed involvement to date and it is encouraging to see a number of positive key principles reflected in the draft.
We have identified some issues, reflected in this response. Indeed the detail of how these principles come forward is a matter for the future, and we would welcome ongoing
involvement in this regard.

CCC is broadly supportive of the vision and objectives and see the SPD as an opportunity to lock in key principles that will benefit sustainable and safe movement in and around the site. A summary of our view is provided below, followed by a commentary on specific sections of the document.

SUMMARY

Walking and Cycling
* CCC supports the principle of exploring cycle routes and pedestrian connectivity through Fitzroy Street and Burleigh Street, as well as other entrances to the Grafton Centre. Careful consideration of cycle parking will be needed to ensure enough provision is provided, whilst ensuring location of parking is convenient, but does not detract from the streetscape.

* It is important to establish the hierarchy of routes for pedestrians, cyclists and vehicles.
The removal of cycling restrictions should be carefully considered in conjunction with appropriate provision of cycle lane infrastructure and how this hierarchy can work in
harmony with pedestrian routes, especially cross-cutting from opposite sides of the
streets. Consideration should also be given to ensuring cycle speeds remain low where cycling is allowed to prevent conflicts between pedestrian users and associated safety implications.

* CCC supports the need for wayfinding, both in the short term and as the development progresses to ensure smooth and confident movements across and around the Grafton Centre area, supported by positive streetscaping and accessible routes for both the mobile and mobility impaired.

Connectivity with East Road and Newmarket Road
* CCC supports the need to work in close partnership with the Greater Cambridge Partnership (GCP) and in particular the City Access team. The connectivity of the site with East Road should be improved and support a holistic approach to a new bus interchange and improved pedestrian experience between this and the Grafton Centre site.

* The potential to reduce the width of East Road carriageway would support this aim, however the wider impact of these changes would need to be further investigated through a traffic assessment and working closely with the GCP.

Public Transport
* CCC recognises opportunities to improve the public transport interaction with the site and the opportunity for a more attractive arrival environment. Changes to the public transport arrangements should be discussed in detail with the public transport operator Stagecoach, and CCC public transport leads.

Taxi Movements
* The County Council are not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

* Given the above, consideration should be given to a more appropriate location for taxi pick up and drop off - but taxis should not be allowed in any areas that are currently pedestrianised.

Car Parking Policy
* Redevelopment of the existing deck car park in Grafton West to provide same number of spaces in a single basement level would enhance the area whilst maintaining current level of spaces. This supports better connectivity to/from the site to Newmarket Road, with a strong emphasis on creating a safer passage between these areas.

* CCC supports the need for electric charging points, and this should also be encouraged in any redevelopment of the retail/public car parks.

REVIEW OF SPD DOCUMENT

1.4 Planning policy context

"Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as an increase in cycle parking through additional managed cycle parking facility, and with no increase in car parking above current levels".

This statement implies that current short stay cycle parking levels will remain as existing and additional cycle parking will be provided through an additional managed facility. It is
important that sufficient short term cycle parking is provided close to each retail facility.
Inadequate levels or poorly located cycle parking can result in cycles being locked to street furniture or in more severe cases cyclists not calling at the retail offer in the area or choosing not to cycle. It must be demonstrated that adequate cycle parking is being provided for short term convenience shoppers within the immediate vicinity of the retail offer and long term cycle parking for the employees of the facilities and long stay shoppers.

2.2.8 - Relocating the bus stops from the current bus interchange to East Road would potentially dis-benefit public transport users travelling to/from the Grafton Area as they will need to cross East Road rather than being dropped at the entrance to the Grafton Centre. Whilst supportive of the principle of improving the public transport arrangements, this will require further discussion with the operator and CCC as to how it can be best achieved.

Cycle routes and parking
2.2.10 - The SPD should make allowances for short stay cycle parking close to retail entrances and in order to facilitate current levels and proposed demand.

2.2.16 - CCC has previously requested that the servicing assessment (referred to in this section of the SPD) was to be provided to the County Council detailing the current servicing needs of businesses within the Grafton area to provide evidence to the statement:
'It is likely the existing full extent of the service areas is no longer required by the centre and the potential for public realm improvements and areas of redevelopment should be explored'.

In developing the SPD, there have been discussions about how the servicing demand / requirements might change in future. These changes are currently new concepts that are in the process or early stages of being developed. Any changes to servicing operations will need to be evidenced and ensure that they are futureproofed, thus at this stage the County Council recommend that the service areas be retained. The County Council do not support additional servicing on street and are concerned by additional conflicts that this could result in.

2.7.4 - 'create a better frontage and pedestrian environment along East Road that is no longer dominated by traffic'
The County Council recognises that the developer identifies this as a potential opportunity to change the form of East Road, however this requires further consideration with both CCC and Greater Cambridge Partnership following the outcomes of the access study.

4.2.1 - the reinstatement of connections from Fitzroy Street to East Road is still very vague. The County Council are not supportive of the reinstatement of Fitzroy Street and Burleigh Street for motorised vehicular traffic due to safety implications for vulnerable road users.

Pedestrian and cycle connectivity
4.5.4 - The reinstatement of carriageway for use by motorised vehicles is not supported by the County Council. CCC have previously advised that the Burleigh Street and Fitzroy Street design options will need to be discussed with both the walking/ cycling officer, cycle groups and mobility groups, and that these views should be fed into the SPD process. Did these meetings take place?

Public transport
4.2.15 - The proposals for buses stopping on East Road need to be discussed in more detail with bus operators and Public Transport Officers.

The SPD includes reference to working closely with Greater Cambridge Partnership but should go on to identify extending services into the evenings to serve the Grafton Area.


Cycle parking

Cycle parking provision should be compared to anticipated demand to identify whether what is proposed is sufficient. This has not been referred to in the SPD. It is important that it is demonstrated that both the short and long stay parking are sufficient to cater for demand. It is important that short stay parking levels be comparable to existing and be sufficient when compared to demand to avoid cycles being locked to street furniture etc.

4.4.24 and 4.4.28 - The County Council is not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

During the workshops locals raised issue with servicing on street currently. With the new developments, intensification of use and potential infilling of areas, there are anticipated to be additional demand for retail and other facilities in the area resulting in additional pedestrians, cyclists and public transport users being attracted to the area and potentially conflicting with existing servicing, which could potentially be worsened through the introduction of additional servicing on street.

4.5.4 - The County Council are not supportive of the introduction of taxis on Fitzroy Street and Burleigh Street. CCC have previously suggested that use of the service areas (Burleigh Place) by taxis out of hours may be an acceptable way of allowing taxis into the area without allowing access into the pedestrianised area of Fitzroy Street and Burleigh Street. However, this doesn't appear to have been carried through into the SPD.

CCC HIGHWAYS COMMENTS Planning policy context
1.4 "Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as a managed cycle parking facility, and with no increase in car parking above current levels";
* How will this be achieved by removal of the current, convenient on-street cycle parking just outside the shops and reintroduction of conflict with motor vehicles on
Fitzroy Street and Burleigh Street?

"Improve the public realm along Fitzroy Street and Burleigh Street, by removing unnecessary
signage and street furniture, and using a simple and durable palette of materials";
* How will this be achieved if more traffic regulation and enforcement would be required?
* How will this be maintained in the long term, given current financial constraints?

Parking
2.2.4 - The site is within a Controlled Parking Zone (CPZ) which means on street parking is restricted at certain times of day.
* The area is also subject to a Residents' Parking Scheme. Residents of any
subsequent development would not be eligible for Residents' Permits.

Cycle routes and parking
2.2.12 - The location and amount of cycle parking will need to be carefully reviewed as part of this SPD.
* This statement should include the stated intention that this must be as, or more, convenient to use than that which currently exists.

2.7.5 - Movement and access: Adapt and redevelop the service areas to the Grafton
Shopping centre to better integrate the shopping centre into its context.
* Should this not also include the aspiration to provide effective, efficient servicing?

Review the car parking requirement and redevelop the Grafton West Car Park.
* Surely the redevelopment should be a provisional aspiration if demonstrated to be appropriate?

4.2.18 Longer-term proposals for servicing assume that normal retail and leisure units could be serviced from key primary streets based on an agreed management strategy including core servicing hours and restrictions on maximum sizes of vehicle as appropriate.
* The reintroduction of motor vehicles, or increased servicing utilising Fitzroy Street or
Burleigh Street is seen as a retrograde step. These streets were pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Surely the aspiration should be to remove the conflict between pedestrians, cyclists and servicing vehicles, rather than manage an increased amount?

Car parking - residential and office uses
4.2.24 Cambridge City Council's car parking standards are expressed as maximum
standards in line with national guidance
* This is no longer National Guidance - please refer to the NPPF
* Residents will not have access to Residents' Permits (see above)

4.2.24 Subject to further discussion and liaison with the County Council, there is an aspiration to create an integrated approach to movement on Fitzroy Street and Burleigh Street. This could involve improved management of servicing where this occurs on street, potential for the introduction of out of hours taxi operation, cycling and other streetscape improvements.
* Servicing activity on Fitzroy Street would take place out of hours and would require enforcement, potentially utilising ANPR cameras.
* Provision for a contraflow cycle lane on Fitzroy Street to accommodate cyclists throughout the day (24/7, not restricted access as currently) is also key.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Figure 41 shows a pedestrian crossing in the junction of Burleigh Street with East
Road. If Burleigh Street is open to vehicular traffic, this is undeliverable on several levels, not least of which is highway safety.
* Provision of a segregated cycleway in the pedestrian area is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space reserved for their use.

4.5.3 Subject to further assessment, proposals should demonstrate an integrated approach to cyclist and pedestrian movement including the creation of defined footways and shared surfaces. The pavements should accommodate primary pedestrian movements and accommodate other functions such as al-fresco eating and occasional market stalls. The re- instated carriageways could have the character of a shared surface, enabling informal negotiation between users including pedestrians and cyclists.

* How do you have both footways and shared surfaces? A scheme can either be shared surface/space or segregated, not both.

* Provision of segregation in what is now a pedestrianised is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space

reserved for their use. Pedestrians will be expected to keep to the footways as identified. This downgrades the position of the pedestrian within the user hierarchy as defined in Manual for Streets, in an area where place should be dominant over transport function.

4.5.4 It is proposed, subject to more detailed design and assessment that taxis could operate on Fitzroy Street and Burleigh Street outside of core hours. The delivery of these public realm improvements should be linked to the adjacent development proposals.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.

* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.

Thank you for consulting Cambridgeshire County Council (CCC) on the draft Grafton Area of Major Change Supplementary Planning Document 2017. CCC has welcomed involvement to date and it is encouraging to see a number of positive key principles reflected in the draft.
We have identified some issues, reflected in this response. Indeed the detail of how these principles come forward is a matter for the future, and we would welcome ongoing
involvement in this regard.

CCC is broadly supportive of the vision and objectives and see the SPD as an opportunity to lock in key principles that will benefit sustainable and safe movement in and around the site. A summary of our view is provided below, followed by a commentary on specific sections of the document.

SUMMARY

Walking and Cycling
* CCC supports the principle of exploring cycle routes and pedestrian connectivity through Fitzroy Street and Burleigh Street, as well as other entrances to the Grafton Centre. Careful consideration of cycle parking will be needed to ensure enough provision is provided, whilst ensuring location of parking is convenient, but does not detract from the streetscape.

* It is important to establish the hierarchy of routes for pedestrians, cyclists and vehicles.
The removal of cycling restrictions should be carefully considered in conjunction with appropriate provision of cycle lane infrastructure and how this hierarchy can work in
harmony with pedestrian routes, especially cross-cutting from opposite sides of the
streets. Consideration should also be given to ensuring cycle speeds remain low where cycling is allowed to prevent conflicts between pedestrian users and associated safety implications.

* CCC supports the need for wayfinding, both in the short term and as the development progresses to ensure smooth and confident movements across and around the Grafton Centre area, supported by positive streetscaping and accessible routes for both the mobile and mobility impaired.

Connectivity with East Road and Newmarket Road
* CCC supports the need to work in close partnership with the Greater Cambridge Partnership (GCP) and in particular the City Access team. The connectivity of the site with East Road should be improved and support a holistic approach to a new bus interchange and improved pedestrian experience between this and the Grafton Centre site.

* The potential to reduce the width of East Road carriageway would support this aim, however the wider impact of these changes would need to be further investigated through a traffic assessment and working closely with the GCP.

Public Transport
* CCC recognises opportunities to improve the public transport interaction with the site and the opportunity for a more attractive arrival environment. Changes to the public transport arrangements should be discussed in detail with the public transport operator Stagecoach, and CCC public transport leads.

Taxi Movements
* The County Council are not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

* Given the above, consideration should be given to a more appropriate location for taxi pick up and drop off - but taxis should not be allowed in any areas that are currently pedestrianised.

Car Parking Policy
* Redevelopment of the existing deck car park in Grafton West to provide same number of spaces in a single basement level would enhance the area whilst maintaining current level of spaces. This supports better connectivity to/from the site to Newmarket Road, with a strong emphasis on creating a safer passage between these areas.

* CCC supports the need for electric charging points, and this should also be encouraged in any redevelopment of the retail/public car parks.

REVIEW OF SPD DOCUMENT

1.4 Planning policy context

"Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as an increase in cycle parking through additional managed cycle parking facility, and with no increase in car parking above current levels".

This statement implies that current short stay cycle parking levels will remain as existing and additional cycle parking will be provided through an additional managed facility. It is
important that sufficient short term cycle parking is provided close to each retail facility.
Inadequate levels or poorly located cycle parking can result in cycles being locked to street furniture or in more severe cases cyclists not calling at the retail offer in the area or choosing not to cycle. It must be demonstrated that adequate cycle parking is being provided for short term convenience shoppers within the immediate vicinity of the retail offer and long term cycle parking for the employees of the facilities and long stay shoppers.

2.2.8 - Relocating the bus stops from the current bus interchange to East Road would potentially dis-benefit public transport users travelling to/from the Grafton Area as they will need to cross East Road rather than being dropped at the entrance to the Grafton Centre. Whilst supportive of the principle of improving the public transport arrangements, this will require further discussion with the operator and CCC as to how it can be best achieved.

Cycle routes and parking
2.2.10 - The SPD should make allowances for short stay cycle parking close to retail entrances and in order to facilitate current levels and proposed demand.

2.2.16 - CCC has previously requested that the servicing assessment (referred to in this section of the SPD) was to be provided to the County Council detailing the current servicing needs of businesses within the Grafton area to provide evidence to the statement:
'It is likely the existing full extent of the service areas is no longer required by the centre and the potential for public realm improvements and areas of redevelopment should be explored'.

In developing the SPD, there have been discussions about how the servicing demand / requirements might change in future. These changes are currently new concepts that are in the process or early stages of being developed. Any changes to servicing operations will need to be evidenced and ensure that they are futureproofed, thus at this stage the County Council recommend that the service areas be retained. The County Council do not support additional servicing on street and are concerned by additional conflicts that this could result in.

2.7.4 - 'create a better frontage and pedestrian environment along East Road that is no longer dominated by traffic'
The County Council recognises that the developer identifies this as a potential opportunity to change the form of East Road, however this requires further consideration with both CCC and Greater Cambridge Partnership following the outcomes of the access study.

4.2.1 - the reinstatement of connections from Fitzroy Street to East Road is still very vague. The County Council are not supportive of the reinstatement of Fitzroy Street and Burleigh Street for motorised vehicular traffic due to safety implications for vulnerable road users.

Pedestrian and cycle connectivity
4.5.4 - The reinstatement of carriageway for use by motorised vehicles is not supported by the County Council. CCC have previously advised that the Burleigh Street and Fitzroy Street design options will need to be discussed with both the walking/ cycling officer, cycle groups and mobility groups, and that these views should be fed into the SPD process. Did these meetings take place?

Public transport
4.2.15 - The proposals for buses stopping on East Road need to be discussed in more detail with bus operators and Public Transport Officers.

The SPD includes reference to working closely with Greater Cambridge Partnership but should go on to identify extending services into the evenings to serve the Grafton Area.


Cycle parking

Cycle parking provision should be compared to anticipated demand to identify whether what is proposed is sufficient. This has not been referred to in the SPD. It is important that it is demonstrated that both the short and long stay parking are sufficient to cater for demand. It is important that short stay parking levels be comparable to existing and be sufficient when compared to demand to avoid cycles being locked to street furniture etc.

4.4.24 and 4.4.28 - The County Council is not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

During the workshops locals raised issue with servicing on street currently. With the new developments, intensification of use and potential infilling of areas, there are anticipated to be additional demand for retail and other facilities in the area resulting in additional pedestrians, cyclists and public transport users being attracted to the area and potentially conflicting with existing servicing, which could potentially be worsened through the introduction of additional servicing on street.

4.5.4 - The County Council are not supportive of the introduction of taxis on Fitzroy Street and Burleigh Street. CCC have previously suggested that use of the service areas (Burleigh Place) by taxis out of hours may be an acceptable way of allowing taxis into the area without allowing access into the pedestrianised area of Fitzroy Street and Burleigh Street. However, this doesn't appear to have been carried through into the SPD.

CCC HIGHWAYS COMMENTS Planning policy context
1.4 "Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as a managed cycle parking facility, and with no increase in car parking above current levels";
* How will this be achieved by removal of the current, convenient on-street cycle parking just outside the shops and reintroduction of conflict with motor vehicles on
Fitzroy Street and Burleigh Street?

"Improve the public realm along Fitzroy Street and Burleigh Street, by removing unnecessary
signage and street furniture, and using a simple and durable palette of materials";
* How will this be achieved if more traffic regulation and enforcement would be required?
* How will this be maintained in the long term, given current financial constraints?

Parking
2.2.4 - The site is within a Controlled Parking Zone (CPZ) which means on street parking is restricted at certain times of day.
* The area is also subject to a Residents' Parking Scheme. Residents of any
subsequent development would not be eligible for Residents' Permits.

Cycle routes and parking
2.2.12 - The location and amount of cycle parking will need to be carefully reviewed as part of this SPD.
* This statement should include the stated intention that this must be as, or more, convenient to use than that which currently exists.

2.7.5 - Movement and access: Adapt and redevelop the service areas to the Grafton
Shopping centre to better integrate the shopping centre into its context.
* Should this not also include the aspiration to provide effective, efficient servicing?

Review the car parking requirement and redevelop the Grafton West Car Park.
* Surely the redevelopment should be a provisional aspiration if demonstrated to be appropriate?

4.2.18 Longer-term proposals for servicing assume that normal retail and leisure units could be serviced from key primary streets based on an agreed management strategy including core servicing hours and restrictions on maximum sizes of vehicle as appropriate.
* The reintroduction of motor vehicles, or increased servicing utilising Fitzroy Street or
Burleigh Street is seen as a retrograde step. These streets were pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Surely the aspiration should be to remove the conflict between pedestrians, cyclists and servicing vehicles, rather than manage an increased amount?

Car parking - residential and office uses
4.2.24 Cambridge City Council's car parking standards are expressed as maximum
standards in line with national guidance
* This is no longer National Guidance - please refer to the NPPF
* Residents will not have access to Residents' Permits (see above)

4.2.24 Subject to further discussion and liaison with the County Council, there is an aspiration to create an integrated approach to movement on Fitzroy Street and Burleigh Street. This could involve improved management of servicing where this occurs on street, potential for the introduction of out of hours taxi operation, cycling and other streetscape improvements.
* Servicing activity on Fitzroy Street would take place out of hours and would require enforcement, potentially utilising ANPR cameras.
* Provision for a contraflow cycle lane on Fitzroy Street to accommodate cyclists throughout the day (24/7, not restricted access as currently) is also key.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Figure 41 shows a pedestrian crossing in the junction of Burleigh Street with East
Road. If Burleigh Street is open to vehicular traffic, this is undeliverable on several levels, not least of which is highway safety.
* Provision of a segregated cycleway in the pedestrian area is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space reserved for their use.

4.5.3 Subject to further assessment, proposals should demonstrate an integrated approach to cyclist and pedestrian movement including the creation of defined footways and shared surfaces. The pavements should accommodate primary pedestrian movements and accommodate other functions such as al-fresco eating and occasional market stalls. The re- instated carriageways could have the character of a shared surface, enabling informal negotiation between users including pedestrians and cyclists.

* How do you have both footways and shared surfaces? A scheme can either be shared surface/space or segregated, not both.

* Provision of segregation in what is now a pedestrianised is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space

reserved for their use. Pedestrians will be expected to keep to the footways as identified. This downgrades the position of the pedestrian within the user hierarchy as defined in Manual for Streets, in an area where place should be dominant over transport function.

4.5.4 It is proposed, subject to more detailed design and assessment that taxis could operate on Fitzroy Street and Burleigh Street outside of core hours. The delivery of these public realm improvements should be linked to the adjacent development proposals.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.

* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.

Thank you for consulting Cambridgeshire County Council (CCC) on the draft Grafton Area of Major Change Supplementary Planning Document 2017. CCC has welcomed involvement to date and it is encouraging to see a number of positive key principles reflected in the draft.
We have identified some issues, reflected in this response. Indeed the detail of how these principles come forward is a matter for the future, and we would welcome ongoing
involvement in this regard.

CCC is broadly supportive of the vision and objectives and see the SPD as an opportunity to lock in key principles that will benefit sustainable and safe movement in and around the site. A summary of our view is provided below, followed by a commentary on specific sections of the document.

SUMMARY

Walking and Cycling
* CCC supports the principle of exploring cycle routes and pedestrian connectivity through Fitzroy Street and Burleigh Street, as well as other entrances to the Grafton Centre. Careful consideration of cycle parking will be needed to ensure enough provision is provided, whilst ensuring location of parking is convenient, but does not detract from the streetscape.

* It is important to establish the hierarchy of routes for pedestrians, cyclists and vehicles.
The removal of cycling restrictions should be carefully considered in conjunction with appropriate provision of cycle lane infrastructure and how this hierarchy can work in
harmony with pedestrian routes, especially cross-cutting from opposite sides of the
streets. Consideration should also be given to ensuring cycle speeds remain low where cycling is allowed to prevent conflicts between pedestrian users and associated safety implications.

* CCC supports the need for wayfinding, both in the short term and as the development progresses to ensure smooth and confident movements across and around the Grafton Centre area, supported by positive streetscaping and accessible routes for both the mobile and mobility impaired.

Connectivity with East Road and Newmarket Road
* CCC supports the need to work in close partnership with the Greater Cambridge Partnership (GCP) and in particular the City Access team. The connectivity of the site with East Road should be improved and support a holistic approach to a new bus interchange and improved pedestrian experience between this and the Grafton Centre site.

* The potential to reduce the width of East Road carriageway would support this aim, however the wider impact of these changes would need to be further investigated through a traffic assessment and working closely with the GCP.

Public Transport
* CCC recognises opportunities to improve the public transport interaction with the site and the opportunity for a more attractive arrival environment. Changes to the public transport arrangements should be discussed in detail with the public transport operator Stagecoach, and CCC public transport leads.

Taxi Movements
* The County Council are not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

* Given the above, consideration should be given to a more appropriate location for taxi pick up and drop off - but taxis should not be allowed in any areas that are currently pedestrianised.

Car Parking Policy
* Redevelopment of the existing deck car park in Grafton West to provide same number of spaces in a single basement level would enhance the area whilst maintaining current level of spaces. This supports better connectivity to/from the site to Newmarket Road, with a strong emphasis on creating a safer passage between these areas.

* CCC supports the need for electric charging points, and this should also be encouraged in any redevelopment of the retail/public car parks.

REVIEW OF SPD DOCUMENT

1.4 Planning policy context

"Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as an increase in cycle parking through additional managed cycle parking facility, and with no increase in car parking above current levels".

This statement implies that current short stay cycle parking levels will remain as existing and additional cycle parking will be provided through an additional managed facility. It is
important that sufficient short term cycle parking is provided close to each retail facility.
Inadequate levels or poorly located cycle parking can result in cycles being locked to street furniture or in more severe cases cyclists not calling at the retail offer in the area or choosing not to cycle. It must be demonstrated that adequate cycle parking is being provided for short term convenience shoppers within the immediate vicinity of the retail offer and long term cycle parking for the employees of the facilities and long stay shoppers.

2.2.8 - Relocating the bus stops from the current bus interchange to East Road would potentially dis-benefit public transport users travelling to/from the Grafton Area as they will need to cross East Road rather than being dropped at the entrance to the Grafton Centre. Whilst supportive of the principle of improving the public transport arrangements, this will require further discussion with the operator and CCC as to how it can be best achieved.

Cycle routes and parking
2.2.10 - The SPD should make allowances for short stay cycle parking close to retail entrances and in order to facilitate current levels and proposed demand.

2.2.16 - CCC has previously requested that the servicing assessment (referred to in this section of the SPD) was to be provided to the County Council detailing the current servicing needs of businesses within the Grafton area to provide evidence to the statement:
'It is likely the existing full extent of the service areas is no longer required by the centre and the potential for public realm improvements and areas of redevelopment should be explored'.

In developing the SPD, there have been discussions about how the servicing demand / requirements might change in future. These changes are currently new concepts that are in the process or early stages of being developed. Any changes to servicing operations will need to be evidenced and ensure that they are futureproofed, thus at this stage the County Council recommend that the service areas be retained. The County Council do not support additional servicing on street and are concerned by additional conflicts that this could result in.

2.7.4 - 'create a better frontage and pedestrian environment along East Road that is no longer dominated by traffic'
The County Council recognises that the developer identifies this as a potential opportunity to change the form of East Road, however this requires further consideration with both CCC and Greater Cambridge Partnership following the outcomes of the access study.

4.2.1 - the reinstatement of connections from Fitzroy Street to East Road is still very vague. The County Council are not supportive of the reinstatement of Fitzroy Street and Burleigh Street for motorised vehicular traffic due to safety implications for vulnerable road users.

Pedestrian and cycle connectivity
4.5.4 - The reinstatement of carriageway for use by motorised vehicles is not supported by the County Council. CCC have previously advised that the Burleigh Street and Fitzroy Street design options will need to be discussed with both the walking/ cycling officer, cycle groups and mobility groups, and that these views should be fed into the SPD process. Did these meetings take place?

Public transport
4.2.15 - The proposals for buses stopping on East Road need to be discussed in more detail with bus operators and Public Transport Officers.

The SPD includes reference to working closely with Greater Cambridge Partnership but should go on to identify extending services into the evenings to serve the Grafton Area.


Cycle parking

Cycle parking provision should be compared to anticipated demand to identify whether what is proposed is sufficient. This has not been referred to in the SPD. It is important that it is demonstrated that both the short and long stay parking are sufficient to cater for demand. It is important that short stay parking levels be comparable to existing and be sufficient when compared to demand to avoid cycles being locked to street furniture etc.

4.4.24 and 4.4.28 - The County Council is not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

During the workshops locals raised issue with servicing on street currently. With the new developments, intensification of use and potential infilling of areas, there are anticipated to be additional demand for retail and other facilities in the area resulting in additional pedestrians, cyclists and public transport users being attracted to the area and potentially conflicting with existing servicing, which could potentially be worsened through the introduction of additional servicing on street.

4.5.4 - The County Council are not supportive of the introduction of taxis on Fitzroy Street and Burleigh Street. CCC have previously suggested that use of the service areas (Burleigh Place) by taxis out of hours may be an acceptable way of allowing taxis into the area without allowing access into the pedestrianised area of Fitzroy Street and Burleigh Street. However, this doesn't appear to have been carried through into the SPD.

CCC HIGHWAYS COMMENTS Planning policy context
1.4 "Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as a managed cycle parking facility, and with no increase in car parking above current levels";
* How will this be achieved by removal of the current, convenient on-street cycle parking just outside the shops and reintroduction of conflict with motor vehicles on
Fitzroy Street and Burleigh Street?

"Improve the public realm along Fitzroy Street and Burleigh Street, by removing unnecessary
signage and street furniture, and using a simple and durable palette of materials";
* How will this be achieved if more traffic regulation and enforcement would be required?
* How will this be maintained in the long term, given current financial constraints?

Parking
2.2.4 - The site is within a Controlled Parking Zone (CPZ) which means on street parking is restricted at certain times of day.
* The area is also subject to a Residents' Parking Scheme. Residents of any
subsequent development would not be eligible for Residents' Permits.

Cycle routes and parking
2.2.12 - The location and amount of cycle parking will need to be carefully reviewed as part of this SPD.
* This statement should include the stated intention that this must be as, or more, convenient to use than that which currently exists.

2.7.5 - Movement and access: Adapt and redevelop the service areas to the Grafton
Shopping centre to better integrate the shopping centre into its context.
* Should this not also include the aspiration to provide effective, efficient servicing?

Review the car parking requirement and redevelop the Grafton West Car Park.
* Surely the redevelopment should be a provisional aspiration if demonstrated to be appropriate?

4.2.18 Longer-term proposals for servicing assume that normal retail and leisure units could be serviced from key primary streets based on an agreed management strategy including core servicing hours and restrictions on maximum sizes of vehicle as appropriate.
* The reintroduction of motor vehicles, or increased servicing utilising Fitzroy Street or
Burleigh Street is seen as a retrograde step. These streets were pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Surely the aspiration should be to remove the conflict between pedestrians, cyclists and servicing vehicles, rather than manage an increased amount?

Car parking - residential and office uses
4.2.24 Cambridge City Council's car parking standards are expressed as maximum
standards in line with national guidance
* This is no longer National Guidance - please refer to the NPPF
* Residents will not have access to Residents' Permits (see above)

4.2.24 Subject to further discussion and liaison with the County Council, there is an aspiration to create an integrated approach to movement on Fitzroy Street and Burleigh Street. This could involve improved management of servicing where this occurs on street, potential for the introduction of out of hours taxi operation, cycling and other streetscape improvements.
* Servicing activity on Fitzroy Street would take place out of hours and would require enforcement, potentially utilising ANPR cameras.
* Provision for a contraflow cycle lane on Fitzroy Street to accommodate cyclists throughout the day (24/7, not restricted access as currently) is also key.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Figure 41 shows a pedestrian crossing in the junction of Burleigh Street with East
Road. If Burleigh Street is open to vehicular traffic, this is undeliverable on several levels, not least of which is highway safety.
* Provision of a segregated cycleway in the pedestrian area is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space reserved for their use.

4.5.3 Subject to further assessment, proposals should demonstrate an integrated approach to cyclist and pedestrian movement including the creation of defined footways and shared surfaces. The pavements should accommodate primary pedestrian movements and accommodate other functions such as al-fresco eating and occasional market stalls. The re- instated carriageways could have the character of a shared surface, enabling informal negotiation between users including pedestrians and cyclists.

* How do you have both footways and shared surfaces? A scheme can either be shared surface/space or segregated, not both.

* Provision of segregation in what is now a pedestrianised is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space

reserved for their use. Pedestrians will be expected to keep to the footways as identified. This downgrades the position of the pedestrian within the user hierarchy as defined in Manual for Streets, in an area where place should be dominant over transport function.

4.5.4 It is proposed, subject to more detailed design and assessment that taxis could operate on Fitzroy Street and Burleigh Street outside of core hours. The delivery of these public realm improvements should be linked to the adjacent development proposals.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.

* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.

Thank you for consulting Cambridgeshire County Council (CCC) on the draft Grafton Area of Major Change Supplementary Planning Document 2017. CCC has welcomed involvement to date and it is encouraging to see a number of positive key principles reflected in the draft.
We have identified some issues, reflected in this response. Indeed the detail of how these principles come forward is a matter for the future, and we would welcome ongoing
involvement in this regard.

CCC is broadly supportive of the vision and objectives and see the SPD as an opportunity to lock in key principles that will benefit sustainable and safe movement in and around the site. A summary of our view is provided below, followed by a commentary on specific sections of the document.

SUMMARY

Walking and Cycling
* CCC supports the principle of exploring cycle routes and pedestrian connectivity through Fitzroy Street and Burleigh Street, as well as other entrances to the Grafton Centre. Careful consideration of cycle parking will be needed to ensure enough provision is provided, whilst ensuring location of parking is convenient, but does not detract from the streetscape.

* It is important to establish the hierarchy of routes for pedestrians, cyclists and vehicles.
The removal of cycling restrictions should be carefully considered in conjunction with appropriate provision of cycle lane infrastructure and how this hierarchy can work in
harmony with pedestrian routes, especially cross-cutting from opposite sides of the
streets. Consideration should also be given to ensuring cycle speeds remain low where cycling is allowed to prevent conflicts between pedestrian users and associated safety implications.

* CCC supports the need for wayfinding, both in the short term and as the development progresses to ensure smooth and confident movements across and around the Grafton Centre area, supported by positive streetscaping and accessible routes for both the mobile and mobility impaired.

Connectivity with East Road and Newmarket Road
* CCC supports the need to work in close partnership with the Greater Cambridge Partnership (GCP) and in particular the City Access team. The connectivity of the site with East Road should be improved and support a holistic approach to a new bus interchange and improved pedestrian experience between this and the Grafton Centre site.

* The potential to reduce the width of East Road carriageway would support this aim, however the wider impact of these changes would need to be further investigated through a traffic assessment and working closely with the GCP.

Public Transport
* CCC recognises opportunities to improve the public transport interaction with the site and the opportunity for a more attractive arrival environment. Changes to the public transport arrangements should be discussed in detail with the public transport operator Stagecoach, and CCC public transport leads.

Taxi Movements
* The County Council are not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

* Given the above, consideration should be given to a more appropriate location for taxi pick up and drop off - but taxis should not be allowed in any areas that are currently pedestrianised.

Car Parking Policy
* Redevelopment of the existing deck car park in Grafton West to provide same number of spaces in a single basement level would enhance the area whilst maintaining current level of spaces. This supports better connectivity to/from the site to Newmarket Road, with a strong emphasis on creating a safer passage between these areas.

* CCC supports the need for electric charging points, and this should also be encouraged in any redevelopment of the retail/public car parks.

REVIEW OF SPD DOCUMENT

1.4 Planning policy context

"Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as an increase in cycle parking through additional managed cycle parking facility, and with no increase in car parking above current levels".

This statement implies that current short stay cycle parking levels will remain as existing and additional cycle parking will be provided through an additional managed facility. It is
important that sufficient short term cycle parking is provided close to each retail facility.
Inadequate levels or poorly located cycle parking can result in cycles being locked to street furniture or in more severe cases cyclists not calling at the retail offer in the area or choosing not to cycle. It must be demonstrated that adequate cycle parking is being provided for short term convenience shoppers within the immediate vicinity of the retail offer and long term cycle parking for the employees of the facilities and long stay shoppers.

2.2.8 - Relocating the bus stops from the current bus interchange to East Road would potentially dis-benefit public transport users travelling to/from the Grafton Area as they will need to cross East Road rather than being dropped at the entrance to the Grafton Centre. Whilst supportive of the principle of improving the public transport arrangements, this will require further discussion with the operator and CCC as to how it can be best achieved.

Cycle routes and parking
2.2.10 - The SPD should make allowances for short stay cycle parking close to retail entrances and in order to facilitate current levels and proposed demand.

2.2.16 - CCC has previously requested that the servicing assessment (referred to in this section of the SPD) was to be provided to the County Council detailing the current servicing needs of businesses within the Grafton area to provide evidence to the statement:
'It is likely the existing full extent of the service areas is no longer required by the centre and the potential for public realm improvements and areas of redevelopment should be explored'.

In developing the SPD, there have been discussions about how the servicing demand / requirements might change in future. These changes are currently new concepts that are in the process or early stages of being developed. Any changes to servicing operations will need to be evidenced and ensure that they are futureproofed, thus at this stage the County Council recommend that the service areas be retained. The County Council do not support additional servicing on street and are concerned by additional conflicts that this could result in.

2.7.4 - 'create a better frontage and pedestrian environment along East Road that is no longer dominated by traffic'
The County Council recognises that the developer identifies this as a potential opportunity to change the form of East Road, however this requires further consideration with both CCC and Greater Cambridge Partnership following the outcomes of the access study.

4.2.1 - the reinstatement of connections from Fitzroy Street to East Road is still very vague. The County Council are not supportive of the reinstatement of Fitzroy Street and Burleigh Street for motorised vehicular traffic due to safety implications for vulnerable road users.

Pedestrian and cycle connectivity
4.5.4 - The reinstatement of carriageway for use by motorised vehicles is not supported by the County Council. CCC have previously advised that the Burleigh Street and Fitzroy Street design options will need to be discussed with both the walking/ cycling officer, cycle groups and mobility groups, and that these views should be fed into the SPD process. Did these meetings take place?

Public transport
4.2.15 - The proposals for buses stopping on East Road need to be discussed in more detail with bus operators and Public Transport Officers.

The SPD includes reference to working closely with Greater Cambridge Partnership but should go on to identify extending services into the evenings to serve the Grafton Area.


Cycle parking

Cycle parking provision should be compared to anticipated demand to identify whether what is proposed is sufficient. This has not been referred to in the SPD. It is important that it is demonstrated that both the short and long stay parking are sufficient to cater for demand. It is important that short stay parking levels be comparable to existing and be sufficient when compared to demand to avoid cycles being locked to street furniture etc.

4.4.24 and 4.4.28 - The County Council is not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

During the workshops locals raised issue with servicing on street currently. With the new developments, intensification of use and potential infilling of areas, there are anticipated to be additional demand for retail and other facilities in the area resulting in additional pedestrians, cyclists and public transport users being attracted to the area and potentially conflicting with existing servicing, which could potentially be worsened through the introduction of additional servicing on street.

4.5.4 - The County Council are not supportive of the introduction of taxis on Fitzroy Street and Burleigh Street. CCC have previously suggested that use of the service areas (Burleigh Place) by taxis out of hours may be an acceptable way of allowing taxis into the area without allowing access into the pedestrianised area of Fitzroy Street and Burleigh Street. However, this doesn't appear to have been carried through into the SPD.

CCC HIGHWAYS COMMENTS Planning policy context
1.4 "Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as a managed cycle parking facility, and with no increase in car parking above current levels";
* How will this be achieved by removal of the current, convenient on-street cycle parking just outside the shops and reintroduction of conflict with motor vehicles on
Fitzroy Street and Burleigh Street?

"Improve the public realm along Fitzroy Street and Burleigh Street, by removing unnecessary
signage and street furniture, and using a simple and durable palette of materials";
* How will this be achieved if more traffic regulation and enforcement would be required?
* How will this be maintained in the long term, given current financial constraints?

Parking
2.2.4 - The site is within a Controlled Parking Zone (CPZ) which means on street parking is restricted at certain times of day.
* The area is also subject to a Residents' Parking Scheme. Residents of any
subsequent development would not be eligible for Residents' Permits.

Cycle routes and parking
2.2.12 - The location and amount of cycle parking will need to be carefully reviewed as part of this SPD.
* This statement should include the stated intention that this must be as, or more, convenient to use than that which currently exists.

2.7.5 - Movement and access: Adapt and redevelop the service areas to the Grafton
Shopping centre to better integrate the shopping centre into its context.
* Should this not also include the aspiration to provide effective, efficient servicing?

Review the car parking requirement and redevelop the Grafton West Car Park.
* Surely the redevelopment should be a provisional aspiration if demonstrated to be appropriate?

4.2.18 Longer-term proposals for servicing assume that normal retail and leisure units could be serviced from key primary streets based on an agreed management strategy including core servicing hours and restrictions on maximum sizes of vehicle as appropriate.
* The reintroduction of motor vehicles, or increased servicing utilising Fitzroy Street or
Burleigh Street is seen as a retrograde step. These streets were pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Surely the aspiration should be to remove the conflict between pedestrians, cyclists and servicing vehicles, rather than manage an increased amount?

Car parking - residential and office uses
4.2.24 Cambridge City Council's car parking standards are expressed as maximum
standards in line with national guidance
* This is no longer National Guidance - please refer to the NPPF
* Residents will not have access to Residents' Permits (see above)

4.2.24 Subject to further discussion and liaison with the County Council, there is an aspiration to create an integrated approach to movement on Fitzroy Street and Burleigh Street. This could involve improved management of servicing where this occurs on street, potential for the introduction of out of hours taxi operation, cycling and other streetscape improvements.
* Servicing activity on Fitzroy Street would take place out of hours and would require enforcement, potentially utilising ANPR cameras.
* Provision for a contraflow cycle lane on Fitzroy Street to accommodate cyclists throughout the day (24/7, not restricted access as currently) is also key.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Figure 41 shows a pedestrian crossing in the junction of Burleigh Street with East
Road. If Burleigh Street is open to vehicular traffic, this is undeliverable on several levels, not least of which is highway safety.
* Provision of a segregated cycleway in the pedestrian area is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space reserved for their use.

4.5.3 Subject to further assessment, proposals should demonstrate an integrated approach to cyclist and pedestrian movement including the creation of defined footways and shared surfaces. The pavements should accommodate primary pedestrian movements and accommodate other functions such as al-fresco eating and occasional market stalls. The re- instated carriageways could have the character of a shared surface, enabling informal negotiation between users including pedestrians and cyclists.

* How do you have both footways and shared surfaces? A scheme can either be shared surface/space or segregated, not both.

* Provision of segregation in what is now a pedestrianised is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space

reserved for their use. Pedestrians will be expected to keep to the footways as identified. This downgrades the position of the pedestrian within the user hierarchy as defined in Manual for Streets, in an area where place should be dominant over transport function.

4.5.4 It is proposed, subject to more detailed design and assessment that taxis could operate on Fitzroy Street and Burleigh Street outside of core hours. The delivery of these public realm improvements should be linked to the adjacent development proposals.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.

* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.

Thank you for consulting Cambridgeshire County Council (CCC) on the draft Grafton Area of Major Change Supplementary Planning Document 2017. CCC has welcomed involvement to date and it is encouraging to see a number of positive key principles reflected in the draft.
We have identified some issues, reflected in this response. Indeed the detail of how these principles come forward is a matter for the future, and we would welcome ongoing
involvement in this regard.

CCC is broadly supportive of the vision and objectives and see the SPD as an opportunity to lock in key principles that will benefit sustainable and safe movement in and around the site. A summary of our view is provided below, followed by a commentary on specific sections of the document.

SUMMARY

Walking and Cycling
* CCC supports the principle of exploring cycle routes and pedestrian connectivity through Fitzroy Street and Burleigh Street, as well as other entrances to the Grafton Centre. Careful consideration of cycle parking will be needed to ensure enough provision is provided, whilst ensuring location of parking is convenient, but does not detract from the streetscape.

* It is important to establish the hierarchy of routes for pedestrians, cyclists and vehicles.
The removal of cycling restrictions should be carefully considered in conjunction with appropriate provision of cycle lane infrastructure and how this hierarchy can work in
harmony with pedestrian routes, especially cross-cutting from opposite sides of the
streets. Consideration should also be given to ensuring cycle speeds remain low where cycling is allowed to prevent conflicts between pedestrian users and associated safety implications.

* CCC supports the need for wayfinding, both in the short term and as the development progresses to ensure smooth and confident movements across and around the Grafton Centre area, supported by positive streetscaping and accessible routes for both the mobile and mobility impaired.

Connectivity with East Road and Newmarket Road
* CCC supports the need to work in close partnership with the Greater Cambridge Partnership (GCP) and in particular the City Access team. The connectivity of the site with East Road should be improved and support a holistic approach to a new bus interchange and improved pedestrian experience between this and the Grafton Centre site.

* The potential to reduce the width of East Road carriageway would support this aim, however the wider impact of these changes would need to be further investigated through a traffic assessment and working closely with the GCP.

Public Transport
* CCC recognises opportunities to improve the public transport interaction with the site and the opportunity for a more attractive arrival environment. Changes to the public transport arrangements should be discussed in detail with the public transport operator Stagecoach, and CCC public transport leads.

Taxi Movements
* The County Council are not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

* Given the above, consideration should be given to a more appropriate location for taxi pick up and drop off - but taxis should not be allowed in any areas that are currently pedestrianised.

Car Parking Policy
* Redevelopment of the existing deck car park in Grafton West to provide same number of spaces in a single basement level would enhance the area whilst maintaining current level of spaces. This supports better connectivity to/from the site to Newmarket Road, with a strong emphasis on creating a safer passage between these areas.

* CCC supports the need for electric charging points, and this should also be encouraged in any redevelopment of the retail/public car parks.

REVIEW OF SPD DOCUMENT

1.4 Planning policy context

"Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as an increase in cycle parking through additional managed cycle parking facility, and with no increase in car parking above current levels".

This statement implies that current short stay cycle parking levels will remain as existing and additional cycle parking will be provided through an additional managed facility. It is
important that sufficient short term cycle parking is provided close to each retail facility.
Inadequate levels or poorly located cycle parking can result in cycles being locked to street furniture or in more severe cases cyclists not calling at the retail offer in the area or choosing not to cycle. It must be demonstrated that adequate cycle parking is being provided for short term convenience shoppers within the immediate vicinity of the retail offer and long term cycle parking for the employees of the facilities and long stay shoppers.

2.2.8 - Relocating the bus stops from the current bus interchange to East Road would potentially dis-benefit public transport users travelling to/from the Grafton Area as they will need to cross East Road rather than being dropped at the entrance to the Grafton Centre. Whilst supportive of the principle of improving the public transport arrangements, this will require further discussion with the operator and CCC as to how it can be best achieved.

Cycle routes and parking
2.2.10 - The SPD should make allowances for short stay cycle parking close to retail entrances and in order to facilitate current levels and proposed demand.

2.2.16 - CCC has previously requested that the servicing assessment (referred to in this section of the SPD) was to be provided to the County Council detailing the current servicing needs of businesses within the Grafton area to provide evidence to the statement:
'It is likely the existing full extent of the service areas is no longer required by the centre and the potential for public realm improvements and areas of redevelopment should be explored'.

In developing the SPD, there have been discussions about how the servicing demand / requirements might change in future. These changes are currently new concepts that are in the process or early stages of being developed. Any changes to servicing operations will need to be evidenced and ensure that they are futureproofed, thus at this stage the County Council recommend that the service areas be retained. The County Council do not support additional servicing on street and are concerned by additional conflicts that this could result in.

2.7.4 - 'create a better frontage and pedestrian environment along East Road that is no longer dominated by traffic'
The County Council recognises that the developer identifies this as a potential opportunity to change the form of East Road, however this requires further consideration with both CCC and Greater Cambridge Partnership following the outcomes of the access study.

4.2.1 - the reinstatement of connections from Fitzroy Street to East Road is still very vague. The County Council are not supportive of the reinstatement of Fitzroy Street and Burleigh Street for motorised vehicular traffic due to safety implications for vulnerable road users.

Pedestrian and cycle connectivity
4.5.4 - The reinstatement of carriageway for use by motorised vehicles is not supported by the County Council. CCC have previously advised that the Burleigh Street and Fitzroy Street design options will need to be discussed with both the walking/ cycling officer, cycle groups and mobility groups, and that these views should be fed into the SPD process. Did these meetings take place?

Public transport
4.2.15 - The proposals for buses stopping on East Road need to be discussed in more detail with bus operators and Public Transport Officers.

The SPD includes reference to working closely with Greater Cambridge Partnership but should go on to identify extending services into the evenings to serve the Grafton Area.


Cycle parking

Cycle parking provision should be compared to anticipated demand to identify whether what is proposed is sufficient. This has not been referred to in the SPD. It is important that it is demonstrated that both the short and long stay parking are sufficient to cater for demand. It is important that short stay parking levels be comparable to existing and be sufficient when compared to demand to avoid cycles being locked to street furniture etc.

4.4.24 and 4.4.28 - The County Council is not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

During the workshops locals raised issue with servicing on street currently. With the new developments, intensification of use and potential infilling of areas, there are anticipated to be additional demand for retail and other facilities in the area resulting in additional pedestrians, cyclists and public transport users being attracted to the area and potentially conflicting with existing servicing, which could potentially be worsened through the introduction of additional servicing on street.

4.5.4 - The County Council are not supportive of the introduction of taxis on Fitzroy Street and Burleigh Street. CCC have previously suggested that use of the service areas (Burleigh Place) by taxis out of hours may be an acceptable way of allowing taxis into the area without allowing access into the pedestrianised area of Fitzroy Street and Burleigh Street. However, this doesn't appear to have been carried through into the SPD.

CCC HIGHWAYS COMMENTS Planning policy context
1.4 "Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as a managed cycle parking facility, and with no increase in car parking above current levels";
* How will this be achieved by removal of the current, convenient on-street cycle parking just outside the shops and reintroduction of conflict with motor vehicles on
Fitzroy Street and Burleigh Street?

"Improve the public realm along Fitzroy Street and Burleigh Street, by removing unnecessary
signage and street furniture, and using a simple and durable palette of materials";
* How will this be achieved if more traffic regulation and enforcement would be required?
* How will this be maintained in the long term, given current financial constraints?

Parking
2.2.4 - The site is within a Controlled Parking Zone (CPZ) which means on street parking is restricted at certain times of day.
* The area is also subject to a Residents' Parking Scheme. Residents of any
subsequent development would not be eligible for Residents' Permits.

Cycle routes and parking
2.2.12 - The location and amount of cycle parking will need to be carefully reviewed as part of this SPD.
* This statement should include the stated intention that this must be as, or more, convenient to use than that which currently exists.

2.7.5 - Movement and access: Adapt and redevelop the service areas to the Grafton
Shopping centre to better integrate the shopping centre into its context.
* Should this not also include the aspiration to provide effective, efficient servicing?

Review the car parking requirement and redevelop the Grafton West Car Park.
* Surely the redevelopment should be a provisional aspiration if demonstrated to be appropriate?

4.2.18 Longer-term proposals for servicing assume that normal retail and leisure units could be serviced from key primary streets based on an agreed management strategy including core servicing hours and restrictions on maximum sizes of vehicle as appropriate.
* The reintroduction of motor vehicles, or increased servicing utilising Fitzroy Street or
Burleigh Street is seen as a retrograde step. These streets were pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Surely the aspiration should be to remove the conflict between pedestrians, cyclists and servicing vehicles, rather than manage an increased amount?

Car parking - residential and office uses
4.2.24 Cambridge City Council's car parking standards are expressed as maximum
standards in line with national guidance
* This is no longer National Guidance - please refer to the NPPF
* Residents will not have access to Residents' Permits (see above)

4.2.24 Subject to further discussion and liaison with the County Council, there is an aspiration to create an integrated approach to movement on Fitzroy Street and Burleigh Street. This could involve improved management of servicing where this occurs on street, potential for the introduction of out of hours taxi operation, cycling and other streetscape improvements.
* Servicing activity on Fitzroy Street would take place out of hours and would require enforcement, potentially utilising ANPR cameras.
* Provision for a contraflow cycle lane on Fitzroy Street to accommodate cyclists throughout the day (24/7, not restricted access as currently) is also key.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Figure 41 shows a pedestrian crossing in the junction of Burleigh Street with East
Road. If Burleigh Street is open to vehicular traffic, this is undeliverable on several levels, not least of which is highway safety.
* Provision of a segregated cycleway in the pedestrian area is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space reserved for their use.

4.5.3 Subject to further assessment, proposals should demonstrate an integrated approach to cyclist and pedestrian movement including the creation of defined footways and shared surfaces. The pavements should accommodate primary pedestrian movements and accommodate other functions such as al-fresco eating and occasional market stalls. The re- instated carriageways could have the character of a shared surface, enabling informal negotiation between users including pedestrians and cyclists.

* How do you have both footways and shared surfaces? A scheme can either be shared surface/space or segregated, not both.

* Provision of segregation in what is now a pedestrianised is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space

reserved for their use. Pedestrians will be expected to keep to the footways as identified. This downgrades the position of the pedestrian within the user hierarchy as defined in Manual for Streets, in an area where place should be dominant over transport function.

4.5.4 It is proposed, subject to more detailed design and assessment that taxis could operate on Fitzroy Street and Burleigh Street outside of core hours. The delivery of these public realm improvements should be linked to the adjacent development proposals.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.

* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.

Thank you for consulting Cambridgeshire County Council (CCC) on the draft Grafton Area of Major Change Supplementary Planning Document 2017. CCC has welcomed involvement to date and it is encouraging to see a number of positive key principles reflected in the draft.
We have identified some issues, reflected in this response. Indeed the detail of how these principles come forward is a matter for the future, and we would welcome ongoing
involvement in this regard.

CCC is broadly supportive of the vision and objectives and see the SPD as an opportunity to lock in key principles that will benefit sustainable and safe movement in and around the site. A summary of our view is provided below, followed by a commentary on specific sections of the document.

SUMMARY

Walking and Cycling
* CCC supports the principle of exploring cycle routes and pedestrian connectivity through Fitzroy Street and Burleigh Street, as well as other entrances to the Grafton Centre. Careful consideration of cycle parking will be needed to ensure enough provision is provided, whilst ensuring location of parking is convenient, but does not detract from the streetscape.

* It is important to establish the hierarchy of routes for pedestrians, cyclists and vehicles.
The removal of cycling restrictions should be carefully considered in conjunction with appropriate provision of cycle lane infrastructure and how this hierarchy can work in
harmony with pedestrian routes, especially cross-cutting from opposite sides of the
streets. Consideration should also be given to ensuring cycle speeds remain low where cycling is allowed to prevent conflicts between pedestrian users and associated safety implications.

* CCC supports the need for wayfinding, both in the short term and as the development progresses to ensure smooth and confident movements across and around the Grafton Centre area, supported by positive streetscaping and accessible routes for both the mobile and mobility impaired.

Connectivity with East Road and Newmarket Road
* CCC supports the need to work in close partnership with the Greater Cambridge Partnership (GCP) and in particular the City Access team. The connectivity of the site with East Road should be improved and support a holistic approach to a new bus interchange and improved pedestrian experience between this and the Grafton Centre site.

* The potential to reduce the width of East Road carriageway would support this aim, however the wider impact of these changes would need to be further investigated through a traffic assessment and working closely with the GCP.

Public Transport
* CCC recognises opportunities to improve the public transport interaction with the site and the opportunity for a more attractive arrival environment. Changes to the public transport arrangements should be discussed in detail with the public transport operator Stagecoach, and CCC public transport leads.

Taxi Movements
* The County Council are not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

* Given the above, consideration should be given to a more appropriate location for taxi pick up and drop off - but taxis should not be allowed in any areas that are currently pedestrianised.

Car Parking Policy
* Redevelopment of the existing deck car park in Grafton West to provide same number of spaces in a single basement level would enhance the area whilst maintaining current level of spaces. This supports better connectivity to/from the site to Newmarket Road, with a strong emphasis on creating a safer passage between these areas.

* CCC supports the need for electric charging points, and this should also be encouraged in any redevelopment of the retail/public car parks.

REVIEW OF SPD DOCUMENT

1.4 Planning policy context

"Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as an increase in cycle parking through additional managed cycle parking facility, and with no increase in car parking above current levels".

This statement implies that current short stay cycle parking levels will remain as existing and additional cycle parking will be provided through an additional managed facility. It is
important that sufficient short term cycle parking is provided close to each retail facility.
Inadequate levels or poorly located cycle parking can result in cycles being locked to street furniture or in more severe cases cyclists not calling at the retail offer in the area or choosing not to cycle. It must be demonstrated that adequate cycle parking is being provided for short term convenience shoppers within the immediate vicinity of the retail offer and long term cycle parking for the employees of the facilities and long stay shoppers.

2.2.8 - Relocating the bus stops from the current bus interchange to East Road would potentially dis-benefit public transport users travelling to/from the Grafton Area as they will need to cross East Road rather than being dropped at the entrance to the Grafton Centre. Whilst supportive of the principle of improving the public transport arrangements, this will require further discussion with the operator and CCC as to how it can be best achieved.

Cycle routes and parking
2.2.10 - The SPD should make allowances for short stay cycle parking close to retail entrances and in order to facilitate current levels and proposed demand.

2.2.16 - CCC has previously requested that the servicing assessment (referred to in this section of the SPD) was to be provided to the County Council detailing the current servicing needs of businesses within the Grafton area to provide evidence to the statement:
'It is likely the existing full extent of the service areas is no longer required by the centre and the potential for public realm improvements and areas of redevelopment should be explored'.

In developing the SPD, there have been discussions about how the servicing demand / requirements might change in future. These changes are currently new concepts that are in the process or early stages of being developed. Any changes to servicing operations will need to be evidenced and ensure that they are futureproofed, thus at this stage the County Council recommend that the service areas be retained. The County Council do not support additional servicing on street and are concerned by additional conflicts that this could result in.

2.7.4 - 'create a better frontage and pedestrian environment along East Road that is no longer dominated by traffic'
The County Council recognises that the developer identifies this as a potential opportunity to change the form of East Road, however this requires further consideration with both CCC and Greater Cambridge Partnership following the outcomes of the access study.

4.2.1 - the reinstatement of connections from Fitzroy Street to East Road is still very vague. The County Council are not supportive of the reinstatement of Fitzroy Street and Burleigh Street for motorised vehicular traffic due to safety implications for vulnerable road users.

Pedestrian and cycle connectivity
4.5.4 - The reinstatement of carriageway for use by motorised vehicles is not supported by the County Council. CCC have previously advised that the Burleigh Street and Fitzroy Street design options will need to be discussed with both the walking/ cycling officer, cycle groups and mobility groups, and that these views should be fed into the SPD process. Did these meetings take place?

Public transport
4.2.15 - The proposals for buses stopping on East Road need to be discussed in more detail with bus operators and Public Transport Officers.

The SPD includes reference to working closely with Greater Cambridge Partnership but should go on to identify extending services into the evenings to serve the Grafton Area.


Cycle parking

Cycle parking provision should be compared to anticipated demand to identify whether what is proposed is sufficient. This has not been referred to in the SPD. It is important that it is demonstrated that both the short and long stay parking are sufficient to cater for demand. It is important that short stay parking levels be comparable to existing and be sufficient when compared to demand to avoid cycles being locked to street furniture etc.

4.4.24 and 4.4.28 - The County Council is not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

During the workshops locals raised issue with servicing on street currently. With the new developments, intensification of use and potential infilling of areas, there are anticipated to be additional demand for retail and other facilities in the area resulting in additional pedestrians, cyclists and public transport users being attracted to the area and potentially conflicting with existing servicing, which could potentially be worsened through the introduction of additional servicing on street.

4.5.4 - The County Council are not supportive of the introduction of taxis on Fitzroy Street and Burleigh Street. CCC have previously suggested that use of the service areas (Burleigh Place) by taxis out of hours may be an acceptable way of allowing taxis into the area without allowing access into the pedestrianised area of Fitzroy Street and Burleigh Street. However, this doesn't appear to have been carried through into the SPD.

CCC HIGHWAYS COMMENTS Planning policy context
1.4 "Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as a managed cycle parking facility, and with no increase in car parking above current levels";
* How will this be achieved by removal of the current, convenient on-street cycle parking just outside the shops and reintroduction of conflict with motor vehicles on
Fitzroy Street and Burleigh Street?

"Improve the public realm along Fitzroy Street and Burleigh Street, by removing unnecessary
signage and street furniture, and using a simple and durable palette of materials";
* How will this be achieved if more traffic regulation and enforcement would be required?
* How will this be maintained in the long term, given current financial constraints?

Parking
2.2.4 - The site is within a Controlled Parking Zone (CPZ) which means on street parking is restricted at certain times of day.
* The area is also subject to a Residents' Parking Scheme. Residents of any
subsequent development would not be eligible for Residents' Permits.

Cycle routes and parking
2.2.12 - The location and amount of cycle parking will need to be carefully reviewed as part of this SPD.
* This statement should include the stated intention that this must be as, or more, convenient to use than that which currently exists.

2.7.5 - Movement and access: Adapt and redevelop the service areas to the Grafton
Shopping centre to better integrate the shopping centre into its context.
* Should this not also include the aspiration to provide effective, efficient servicing?

Review the car parking requirement and redevelop the Grafton West Car Park.
* Surely the redevelopment should be a provisional aspiration if demonstrated to be appropriate?

4.2.18 Longer-term proposals for servicing assume that normal retail and leisure units could be serviced from key primary streets based on an agreed management strategy including core servicing hours and restrictions on maximum sizes of vehicle as appropriate.
* The reintroduction of motor vehicles, or increased servicing utilising Fitzroy Street or
Burleigh Street is seen as a retrograde step. These streets were pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Surely the aspiration should be to remove the conflict between pedestrians, cyclists and servicing vehicles, rather than manage an increased amount?

Car parking - residential and office uses
4.2.24 Cambridge City Council's car parking standards are expressed as maximum
standards in line with national guidance
* This is no longer National Guidance - please refer to the NPPF
* Residents will not have access to Residents' Permits (see above)

4.2.24 Subject to further discussion and liaison with the County Council, there is an aspiration to create an integrated approach to movement on Fitzroy Street and Burleigh Street. This could involve improved management of servicing where this occurs on street, potential for the introduction of out of hours taxi operation, cycling and other streetscape improvements.
* Servicing activity on Fitzroy Street would take place out of hours and would require enforcement, potentially utilising ANPR cameras.
* Provision for a contraflow cycle lane on Fitzroy Street to accommodate cyclists throughout the day (24/7, not restricted access as currently) is also key.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Figure 41 shows a pedestrian crossing in the junction of Burleigh Street with East
Road. If Burleigh Street is open to vehicular traffic, this is undeliverable on several levels, not least of which is highway safety.
* Provision of a segregated cycleway in the pedestrian area is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space reserved for their use.

4.5.3 Subject to further assessment, proposals should demonstrate an integrated approach to cyclist and pedestrian movement including the creation of defined footways and shared surfaces. The pavements should accommodate primary pedestrian movements and accommodate other functions such as al-fresco eating and occasional market stalls. The re- instated carriageways could have the character of a shared surface, enabling informal negotiation between users including pedestrians and cyclists.

* How do you have both footways and shared surfaces? A scheme can either be shared surface/space or segregated, not both.

* Provision of segregation in what is now a pedestrianised is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space

reserved for their use. Pedestrians will be expected to keep to the footways as identified. This downgrades the position of the pedestrian within the user hierarchy as defined in Manual for Streets, in an area where place should be dominant over transport function.

4.5.4 It is proposed, subject to more detailed design and assessment that taxis could operate on Fitzroy Street and Burleigh Street outside of core hours. The delivery of these public realm improvements should be linked to the adjacent development proposals.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.

* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.

Thank you for consulting Cambridgeshire County Council (CCC) on the draft Grafton Area of Major Change Supplementary Planning Document 2017. CCC has welcomed involvement to date and it is encouraging to see a number of positive key principles reflected in the draft.
We have identified some issues, reflected in this response. Indeed the detail of how these principles come forward is a matter for the future, and we would welcome ongoing
involvement in this regard.

CCC is broadly supportive of the vision and objectives and see the SPD as an opportunity to lock in key principles that will benefit sustainable and safe movement in and around the site. A summary of our view is provided below, followed by a commentary on specific sections of the document.

SUMMARY

Walking and Cycling
* CCC supports the principle of exploring cycle routes and pedestrian connectivity through Fitzroy Street and Burleigh Street, as well as other entrances to the Grafton Centre. Careful consideration of cycle parking will be needed to ensure enough provision is provided, whilst ensuring location of parking is convenient, but does not detract from the streetscape.

* It is important to establish the hierarchy of routes for pedestrians, cyclists and vehicles.
The removal of cycling restrictions should be carefully considered in conjunction with appropriate provision of cycle lane infrastructure and how this hierarchy can work in
harmony with pedestrian routes, especially cross-cutting from opposite sides of the
streets. Consideration should also be given to ensuring cycle speeds remain low where cycling is allowed to prevent conflicts between pedestrian users and associated safety implications.

* CCC supports the need for wayfinding, both in the short term and as the development progresses to ensure smooth and confident movements across and around the Grafton Centre area, supported by positive streetscaping and accessible routes for both the mobile and mobility impaired.

Connectivity with East Road and Newmarket Road
* CCC supports the need to work in close partnership with the Greater Cambridge Partnership (GCP) and in particular the City Access team. The connectivity of the site with East Road should be improved and support a holistic approach to a new bus interchange and improved pedestrian experience between this and the Grafton Centre site.

* The potential to reduce the width of East Road carriageway would support this aim, however the wider impact of these changes would need to be further investigated through a traffic assessment and working closely with the GCP.

Public Transport
* CCC recognises opportunities to improve the public transport interaction with the site and the opportunity for a more attractive arrival environment. Changes to the public transport arrangements should be discussed in detail with the public transport operator Stagecoach, and CCC public transport leads.

Taxi Movements
* The County Council are not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

* Given the above, consideration should be given to a more appropriate location for taxi pick up and drop off - but taxis should not be allowed in any areas that are currently pedestrianised.

Car Parking Policy
* Redevelopment of the existing deck car park in Grafton West to provide same number of spaces in a single basement level would enhance the area whilst maintaining current level of spaces. This supports better connectivity to/from the site to Newmarket Road, with a strong emphasis on creating a safer passage between these areas.

* CCC supports the need for electric charging points, and this should also be encouraged in any redevelopment of the retail/public car parks.

REVIEW OF SPD DOCUMENT

1.4 Planning policy context

"Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as an increase in cycle parking through additional managed cycle parking facility, and with no increase in car parking above current levels".

This statement implies that current short stay cycle parking levels will remain as existing and additional cycle parking will be provided through an additional managed facility. It is
important that sufficient short term cycle parking is provided close to each retail facility.
Inadequate levels or poorly located cycle parking can result in cycles being locked to street furniture or in more severe cases cyclists not calling at the retail offer in the area or choosing not to cycle. It must be demonstrated that adequate cycle parking is being provided for short term convenience shoppers within the immediate vicinity of the retail offer and long term cycle parking for the employees of the facilities and long stay shoppers.

2.2.8 - Relocating the bus stops from the current bus interchange to East Road would potentially dis-benefit public transport users travelling to/from the Grafton Area as they will need to cross East Road rather than being dropped at the entrance to the Grafton Centre. Whilst supportive of the principle of improving the public transport arrangements, this will require further discussion with the operator and CCC as to how it can be best achieved.

Cycle routes and parking
2.2.10 - The SPD should make allowances for short stay cycle parking close to retail entrances and in order to facilitate current levels and proposed demand.

2.2.16 - CCC has previously requested that the servicing assessment (referred to in this section of the SPD) was to be provided to the County Council detailing the current servicing needs of businesses within the Grafton area to provide evidence to the statement:
'It is likely the existing full extent of the service areas is no longer required by the centre and the potential for public realm improvements and areas of redevelopment should be explored'.

In developing the SPD, there have been discussions about how the servicing demand / requirements might change in future. These changes are currently new concepts that are in the process or early stages of being developed. Any changes to servicing operations will need to be evidenced and ensure that they are futureproofed, thus at this stage the County Council recommend that the service areas be retained. The County Council do not support additional servicing on street and are concerned by additional conflicts that this could result in.

2.7.4 - 'create a better frontage and pedestrian environment along East Road that is no longer dominated by traffic'
The County Council recognises that the developer identifies this as a potential opportunity to change the form of East Road, however this requires further consideration with both CCC and Greater Cambridge Partnership following the outcomes of the access study.

4.2.1 - the reinstatement of connections from Fitzroy Street to East Road is still very vague. The County Council are not supportive of the reinstatement of Fitzroy Street and Burleigh Street for motorised vehicular traffic due to safety implications for vulnerable road users.

Pedestrian and cycle connectivity
4.5.4 - The reinstatement of carriageway for use by motorised vehicles is not supported by the County Council. CCC have previously advised that the Burleigh Street and Fitzroy Street design options will need to be discussed with both the walking/ cycling officer, cycle groups and mobility groups, and that these views should be fed into the SPD process. Did these meetings take place?

Public transport
4.2.15 - The proposals for buses stopping on East Road need to be discussed in more detail with bus operators and Public Transport Officers.

The SPD includes reference to working closely with Greater Cambridge Partnership but should go on to identify extending services into the evenings to serve the Grafton Area.


Cycle parking

Cycle parking provision should be compared to anticipated demand to identify whether what is proposed is sufficient. This has not been referred to in the SPD. It is important that it is demonstrated that both the short and long stay parking are sufficient to cater for demand. It is important that short stay parking levels be comparable to existing and be sufficient when compared to demand to avoid cycles being locked to street furniture etc.

4.4.24 and 4.4.28 - The County Council is not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

During the workshops locals raised issue with servicing on street currently. With the new developments, intensification of use and potential infilling of areas, there are anticipated to be additional demand for retail and other facilities in the area resulting in additional pedestrians, cyclists and public transport users being attracted to the area and potentially conflicting with existing servicing, which could potentially be worsened through the introduction of additional servicing on street.

4.5.4 - The County Council are not supportive of the introduction of taxis on Fitzroy Street and Burleigh Street. CCC have previously suggested that use of the service areas (Burleigh Place) by taxis out of hours may be an acceptable way of allowing taxis into the area without allowing access into the pedestrianised area of Fitzroy Street and Burleigh Street. However, this doesn't appear to have been carried through into the SPD.

CCC HIGHWAYS COMMENTS Planning policy context
1.4 "Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as a managed cycle parking facility, and with no increase in car parking above current levels";
* How will this be achieved by removal of the current, convenient on-street cycle parking just outside the shops and reintroduction of conflict with motor vehicles on
Fitzroy Street and Burleigh Street?

"Improve the public realm along Fitzroy Street and Burleigh Street, by removing unnecessary
signage and street furniture, and using a simple and durable palette of materials";
* How will this be achieved if more traffic regulation and enforcement would be required?
* How will this be maintained in the long term, given current financial constraints?

Parking
2.2.4 - The site is within a Controlled Parking Zone (CPZ) which means on street parking is restricted at certain times of day.
* The area is also subject to a Residents' Parking Scheme. Residents of any
subsequent development would not be eligible for Residents' Permits.

Cycle routes and parking
2.2.12 - The location and amount of cycle parking will need to be carefully reviewed as part of this SPD.
* This statement should include the stated intention that this must be as, or more, convenient to use than that which currently exists.

2.7.5 - Movement and access: Adapt and redevelop the service areas to the Grafton
Shopping centre to better integrate the shopping centre into its context.
* Should this not also include the aspiration to provide effective, efficient servicing?

Review the car parking requirement and redevelop the Grafton West Car Park.
* Surely the redevelopment should be a provisional aspiration if demonstrated to be appropriate?

4.2.18 Longer-term proposals for servicing assume that normal retail and leisure units could be serviced from key primary streets based on an agreed management strategy including core servicing hours and restrictions on maximum sizes of vehicle as appropriate.
* The reintroduction of motor vehicles, or increased servicing utilising Fitzroy Street or
Burleigh Street is seen as a retrograde step. These streets were pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Surely the aspiration should be to remove the conflict between pedestrians, cyclists and servicing vehicles, rather than manage an increased amount?

Car parking - residential and office uses
4.2.24 Cambridge City Council's car parking standards are expressed as maximum
standards in line with national guidance
* This is no longer National Guidance - please refer to the NPPF
* Residents will not have access to Residents' Permits (see above)

4.2.24 Subject to further discussion and liaison with the County Council, there is an aspiration to create an integrated approach to movement on Fitzroy Street and Burleigh Street. This could involve improved management of servicing where this occurs on street, potential for the introduction of out of hours taxi operation, cycling and other streetscape improvements.
* Servicing activity on Fitzroy Street would take place out of hours and would require enforcement, potentially utilising ANPR cameras.
* Provision for a contraflow cycle lane on Fitzroy Street to accommodate cyclists throughout the day (24/7, not restricted access as currently) is also key.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Figure 41 shows a pedestrian crossing in the junction of Burleigh Street with East
Road. If Burleigh Street is open to vehicular traffic, this is undeliverable on several levels, not least of which is highway safety.
* Provision of a segregated cycleway in the pedestrian area is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space reserved for their use.

4.5.3 Subject to further assessment, proposals should demonstrate an integrated approach to cyclist and pedestrian movement including the creation of defined footways and shared surfaces. The pavements should accommodate primary pedestrian movements and accommodate other functions such as al-fresco eating and occasional market stalls. The re- instated carriageways could have the character of a shared surface, enabling informal negotiation between users including pedestrians and cyclists.

* How do you have both footways and shared surfaces? A scheme can either be shared surface/space or segregated, not both.

* Provision of segregation in what is now a pedestrianised is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space

reserved for their use. Pedestrians will be expected to keep to the footways as identified. This downgrades the position of the pedestrian within the user hierarchy as defined in Manual for Streets, in an area where place should be dominant over transport function.

4.5.4 It is proposed, subject to more detailed design and assessment that taxis could operate on Fitzroy Street and Burleigh Street outside of core hours. The delivery of these public realm improvements should be linked to the adjacent development proposals.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.

* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.

Thank you for consulting Cambridgeshire County Council (CCC) on the draft Grafton Area of Major Change Supplementary Planning Document 2017. CCC has welcomed involvement to date and it is encouraging to see a number of positive key principles reflected in the draft.
We have identified some issues, reflected in this response. Indeed the detail of how these principles come forward is a matter for the future, and we would welcome ongoing
involvement in this regard.

CCC is broadly supportive of the vision and objectives and see the SPD as an opportunity to lock in key principles that will benefit sustainable and safe movement in and around the site. A summary of our view is provided below, followed by a commentary on specific sections of the document.

SUMMARY

Walking and Cycling
* CCC supports the principle of exploring cycle routes and pedestrian connectivity through Fitzroy Street and Burleigh Street, as well as other entrances to the Grafton Centre. Careful consideration of cycle parking will be needed to ensure enough provision is provided, whilst ensuring location of parking is convenient, but does not detract from the streetscape.

* It is important to establish the hierarchy of routes for pedestrians, cyclists and vehicles.
The removal of cycling restrictions should be carefully considered in conjunction with appropriate provision of cycle lane infrastructure and how this hierarchy can work in
harmony with pedestrian routes, especially cross-cutting from opposite sides of the
streets. Consideration should also be given to ensuring cycle speeds remain low where cycling is allowed to prevent conflicts between pedestrian users and associated safety implications.

* CCC supports the need for wayfinding, both in the short term and as the development progresses to ensure smooth and confident movements across and around the Grafton Centre area, supported by positive streetscaping and accessible routes for both the mobile and mobility impaired.

Connectivity with East Road and Newmarket Road
* CCC supports the need to work in close partnership with the Greater Cambridge Partnership (GCP) and in particular the City Access team. The connectivity of the site with East Road should be improved and support a holistic approach to a new bus interchange and improved pedestrian experience between this and the Grafton Centre site.

* The potential to reduce the width of East Road carriageway would support this aim, however the wider impact of these changes would need to be further investigated through a traffic assessment and working closely with the GCP.

Public Transport
* CCC recognises opportunities to improve the public transport interaction with the site and the opportunity for a more attractive arrival environment. Changes to the public transport arrangements should be discussed in detail with the public transport operator Stagecoach, and CCC public transport leads.

Taxi Movements
* The County Council are not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

* Given the above, consideration should be given to a more appropriate location for taxi pick up and drop off - but taxis should not be allowed in any areas that are currently pedestrianised.

Car Parking Policy
* Redevelopment of the existing deck car park in Grafton West to provide same number of spaces in a single basement level would enhance the area whilst maintaining current level of spaces. This supports better connectivity to/from the site to Newmarket Road, with a strong emphasis on creating a safer passage between these areas.

* CCC supports the need for electric charging points, and this should also be encouraged in any redevelopment of the retail/public car parks.

REVIEW OF SPD DOCUMENT

1.4 Planning policy context

"Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as an increase in cycle parking through additional managed cycle parking facility, and with no increase in car parking above current levels".

This statement implies that current short stay cycle parking levels will remain as existing and additional cycle parking will be provided through an additional managed facility. It is
important that sufficient short term cycle parking is provided close to each retail facility.
Inadequate levels or poorly located cycle parking can result in cycles being locked to street furniture or in more severe cases cyclists not calling at the retail offer in the area or choosing not to cycle. It must be demonstrated that adequate cycle parking is being provided for short term convenience shoppers within the immediate vicinity of the retail offer and long term cycle parking for the employees of the facilities and long stay shoppers.

2.2.8 - Relocating the bus stops from the current bus interchange to East Road would potentially dis-benefit public transport users travelling to/from the Grafton Area as they will need to cross East Road rather than being dropped at the entrance to the Grafton Centre. Whilst supportive of the principle of improving the public transport arrangements, this will require further discussion with the operator and CCC as to how it can be best achieved.

Cycle routes and parking
2.2.10 - The SPD should make allowances for short stay cycle parking close to retail entrances and in order to facilitate current levels and proposed demand.

2.2.16 - CCC has previously requested that the servicing assessment (referred to in this section of the SPD) was to be provided to the County Council detailing the current servicing needs of businesses within the Grafton area to provide evidence to the statement:
'It is likely the existing full extent of the service areas is no longer required by the centre and the potential for public realm improvements and areas of redevelopment should be explored'.

In developing the SPD, there have been discussions about how the servicing demand / requirements might change in future. These changes are currently new concepts that are in the process or early stages of being developed. Any changes to servicing operations will need to be evidenced and ensure that they are futureproofed, thus at this stage the County Council recommend that the service areas be retained. The County Council do not support additional servicing on street and are concerned by additional conflicts that this could result in.

2.7.4 - 'create a better frontage and pedestrian environment along East Road that is no longer dominated by traffic'
The County Council recognises that the developer identifies this as a potential opportunity to change the form of East Road, however this requires further consideration with both CCC and Greater Cambridge Partnership following the outcomes of the access study.

4.2.1 - the reinstatement of connections from Fitzroy Street to East Road is still very vague. The County Council are not supportive of the reinstatement of Fitzroy Street and Burleigh Street for motorised vehicular traffic due to safety implications for vulnerable road users.

Pedestrian and cycle connectivity
4.5.4 - The reinstatement of carriageway for use by motorised vehicles is not supported by the County Council. CCC have previously advised that the Burleigh Street and Fitzroy Street design options will need to be discussed with both the walking/ cycling officer, cycle groups and mobility groups, and that these views should be fed into the SPD process. Did these meetings take place?

Public transport
4.2.15 - The proposals for buses stopping on East Road need to be discussed in more detail with bus operators and Public Transport Officers.

The SPD includes reference to working closely with Greater Cambridge Partnership but should go on to identify extending services into the evenings to serve the Grafton Area.


Cycle parking

Cycle parking provision should be compared to anticipated demand to identify whether what is proposed is sufficient. This has not been referred to in the SPD. It is important that it is demonstrated that both the short and long stay parking are sufficient to cater for demand. It is important that short stay parking levels be comparable to existing and be sufficient when compared to demand to avoid cycles being locked to street furniture etc.

4.4.24 and 4.4.28 - The County Council is not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

During the workshops locals raised issue with servicing on street currently. With the new developments, intensification of use and potential infilling of areas, there are anticipated to be additional demand for retail and other facilities in the area resulting in additional pedestrians, cyclists and public transport users being attracted to the area and potentially conflicting with existing servicing, which could potentially be worsened through the introduction of additional servicing on street.

4.5.4 - The County Council are not supportive of the introduction of taxis on Fitzroy Street and Burleigh Street. CCC have previously suggested that use of the service areas (Burleigh Place) by taxis out of hours may be an acceptable way of allowing taxis into the area without allowing access into the pedestrianised area of Fitzroy Street and Burleigh Street. However, this doesn't appear to have been carried through into the SPD.

CCC HIGHWAYS COMMENTS Planning policy context
1.4 "Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as a managed cycle parking facility, and with no increase in car parking above current levels";
* How will this be achieved by removal of the current, convenient on-street cycle parking just outside the shops and reintroduction of conflict with motor vehicles on
Fitzroy Street and Burleigh Street?

"Improve the public realm along Fitzroy Street and Burleigh Street, by removing unnecessary
signage and street furniture, and using a simple and durable palette of materials";
* How will this be achieved if more traffic regulation and enforcement would be required?
* How will this be maintained in the long term, given current financial constraints?

Parking
2.2.4 - The site is within a Controlled Parking Zone (CPZ) which means on street parking is restricted at certain times of day.
* The area is also subject to a Residents' Parking Scheme. Residents of any
subsequent development would not be eligible for Residents' Permits.

Cycle routes and parking
2.2.12 - The location and amount of cycle parking will need to be carefully reviewed as part of this SPD.
* This statement should include the stated intention that this must be as, or more, convenient to use than that which currently exists.

2.7.5 - Movement and access: Adapt and redevelop the service areas to the Grafton
Shopping centre to better integrate the shopping centre into its context.
* Should this not also include the aspiration to provide effective, efficient servicing?

Review the car parking requirement and redevelop the Grafton West Car Park.
* Surely the redevelopment should be a provisional aspiration if demonstrated to be appropriate?

4.2.18 Longer-term proposals for servicing assume that normal retail and leisure units could be serviced from key primary streets based on an agreed management strategy including core servicing hours and restrictions on maximum sizes of vehicle as appropriate.
* The reintroduction of motor vehicles, or increased servicing utilising Fitzroy Street or
Burleigh Street is seen as a retrograde step. These streets were pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Surely the aspiration should be to remove the conflict between pedestrians, cyclists and servicing vehicles, rather than manage an increased amount?

Car parking - residential and office uses
4.2.24 Cambridge City Council's car parking standards are expressed as maximum
standards in line with national guidance
* This is no longer National Guidance - please refer to the NPPF
* Residents will not have access to Residents' Permits (see above)

4.2.24 Subject to further discussion and liaison with the County Council, there is an aspiration to create an integrated approach to movement on Fitzroy Street and Burleigh Street. This could involve improved management of servicing where this occurs on street, potential for the introduction of out of hours taxi operation, cycling and other streetscape improvements.
* Servicing activity on Fitzroy Street would take place out of hours and would require enforcement, potentially utilising ANPR cameras.
* Provision for a contraflow cycle lane on Fitzroy Street to accommodate cyclists throughout the day (24/7, not restricted access as currently) is also key.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Figure 41 shows a pedestrian crossing in the junction of Burleigh Street with East
Road. If Burleigh Street is open to vehicular traffic, this is undeliverable on several levels, not least of which is highway safety.
* Provision of a segregated cycleway in the pedestrian area is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space reserved for their use.

4.5.3 Subject to further assessment, proposals should demonstrate an integrated approach to cyclist and pedestrian movement including the creation of defined footways and shared surfaces. The pavements should accommodate primary pedestrian movements and accommodate other functions such as al-fresco eating and occasional market stalls. The re- instated carriageways could have the character of a shared surface, enabling informal negotiation between users including pedestrians and cyclists.

* How do you have both footways and shared surfaces? A scheme can either be shared surface/space or segregated, not both.

* Provision of segregation in what is now a pedestrianised is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space

reserved for their use. Pedestrians will be expected to keep to the footways as identified. This downgrades the position of the pedestrian within the user hierarchy as defined in Manual for Streets, in an area where place should be dominant over transport function.

4.5.4 It is proposed, subject to more detailed design and assessment that taxis could operate on Fitzroy Street and Burleigh Street outside of core hours. The delivery of these public realm improvements should be linked to the adjacent development proposals.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.

* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.

Thank you for consulting Cambridgeshire County Council (CCC) on the draft Grafton Area of Major Change Supplementary Planning Document 2017. CCC has welcomed involvement to date and it is encouraging to see a number of positive key principles reflected in the draft.
We have identified some issues, reflected in this response. Indeed the detail of how these principles come forward is a matter for the future, and we would welcome ongoing
involvement in this regard.

CCC is broadly supportive of the vision and objectives and see the SPD as an opportunity to lock in key principles that will benefit sustainable and safe movement in and around the site. A summary of our view is provided below, followed by a commentary on specific sections of the document.

SUMMARY

Walking and Cycling
* CCC supports the principle of exploring cycle routes and pedestrian connectivity through Fitzroy Street and Burleigh Street, as well as other entrances to the Grafton Centre. Careful consideration of cycle parking will be needed to ensure enough provision is provided, whilst ensuring location of parking is convenient, but does not detract from the streetscape.

* It is important to establish the hierarchy of routes for pedestrians, cyclists and vehicles.
The removal of cycling restrictions should be carefully considered in conjunction with appropriate provision of cycle lane infrastructure and how this hierarchy can work in
harmony with pedestrian routes, especially cross-cutting from opposite sides of the
streets. Consideration should also be given to ensuring cycle speeds remain low where cycling is allowed to prevent conflicts between pedestrian users and associated safety implications.

* CCC supports the need for wayfinding, both in the short term and as the development progresses to ensure smooth and confident movements across and around the Grafton Centre area, supported by positive streetscaping and accessible routes for both the mobile and mobility impaired.

Connectivity with East Road and Newmarket Road
* CCC supports the need to work in close partnership with the Greater Cambridge Partnership (GCP) and in particular the City Access team. The connectivity of the site with East Road should be improved and support a holistic approach to a new bus interchange and improved pedestrian experience between this and the Grafton Centre site.

* The potential to reduce the width of East Road carriageway would support this aim, however the wider impact of these changes would need to be further investigated through a traffic assessment and working closely with the GCP.

Public Transport
* CCC recognises opportunities to improve the public transport interaction with the site and the opportunity for a more attractive arrival environment. Changes to the public transport arrangements should be discussed in detail with the public transport operator Stagecoach, and CCC public transport leads.

Taxi Movements
* The County Council are not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

* Given the above, consideration should be given to a more appropriate location for taxi pick up and drop off - but taxis should not be allowed in any areas that are currently pedestrianised.

Car Parking Policy
* Redevelopment of the existing deck car park in Grafton West to provide same number of spaces in a single basement level would enhance the area whilst maintaining current level of spaces. This supports better connectivity to/from the site to Newmarket Road, with a strong emphasis on creating a safer passage between these areas.

* CCC supports the need for electric charging points, and this should also be encouraged in any redevelopment of the retail/public car parks.

REVIEW OF SPD DOCUMENT

1.4 Planning policy context

"Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as an increase in cycle parking through additional managed cycle parking facility, and with no increase in car parking above current levels".

This statement implies that current short stay cycle parking levels will remain as existing and additional cycle parking will be provided through an additional managed facility. It is
important that sufficient short term cycle parking is provided close to each retail facility.
Inadequate levels or poorly located cycle parking can result in cycles being locked to street furniture or in more severe cases cyclists not calling at the retail offer in the area or choosing not to cycle. It must be demonstrated that adequate cycle parking is being provided for short term convenience shoppers within the immediate vicinity of the retail offer and long term cycle parking for the employees of the facilities and long stay shoppers.

2.2.8 - Relocating the bus stops from the current bus interchange to East Road would potentially dis-benefit public transport users travelling to/from the Grafton Area as they will need to cross East Road rather than being dropped at the entrance to the Grafton Centre. Whilst supportive of the principle of improving the public transport arrangements, this will require further discussion with the operator and CCC as to how it can be best achieved.

Cycle routes and parking
2.2.10 - The SPD should make allowances for short stay cycle parking close to retail entrances and in order to facilitate current levels and proposed demand.

2.2.16 - CCC has previously requested that the servicing assessment (referred to in this section of the SPD) was to be provided to the County Council detailing the current servicing needs of businesses within the Grafton area to provide evidence to the statement:
'It is likely the existing full extent of the service areas is no longer required by the centre and the potential for public realm improvements and areas of redevelopment should be explored'.

In developing the SPD, there have been discussions about how the servicing demand / requirements might change in future. These changes are currently new concepts that are in the process or early stages of being developed. Any changes to servicing operations will need to be evidenced and ensure that they are futureproofed, thus at this stage the County Council recommend that the service areas be retained. The County Council do not support additional servicing on street and are concerned by additional conflicts that this could result in.

2.7.4 - 'create a better frontage and pedestrian environment along East Road that is no longer dominated by traffic'
The County Council recognises that the developer identifies this as a potential opportunity to change the form of East Road, however this requires further consideration with both CCC and Greater Cambridge Partnership following the outcomes of the access study.

4.2.1 - the reinstatement of connections from Fitzroy Street to East Road is still very vague. The County Council are not supportive of the reinstatement of Fitzroy Street and Burleigh Street for motorised vehicular traffic due to safety implications for vulnerable road users.

Pedestrian and cycle connectivity
4.5.4 - The reinstatement of carriageway for use by motorised vehicles is not supported by the County Council. CCC have previously advised that the Burleigh Street and Fitzroy Street design options will need to be discussed with both the walking/ cycling officer, cycle groups and mobility groups, and that these views should be fed into the SPD process. Did these meetings take place?

Public transport
4.2.15 - The proposals for buses stopping on East Road need to be discussed in more detail with bus operators and Public Transport Officers.

The SPD includes reference to working closely with Greater Cambridge Partnership but should go on to identify extending services into the evenings to serve the Grafton Area.


Cycle parking

Cycle parking provision should be compared to anticipated demand to identify whether what is proposed is sufficient. This has not been referred to in the SPD. It is important that it is demonstrated that both the short and long stay parking are sufficient to cater for demand. It is important that short stay parking levels be comparable to existing and be sufficient when compared to demand to avoid cycles being locked to street furniture etc.

4.4.24 and 4.4.28 - The County Council is not supportive of taxis on a through route between Fitzroy Street and East Road, this would result in rat running and safety concerns for pedestrians and cyclists.

During the workshops locals raised issue with servicing on street currently. With the new developments, intensification of use and potential infilling of areas, there are anticipated to be additional demand for retail and other facilities in the area resulting in additional pedestrians, cyclists and public transport users being attracted to the area and potentially conflicting with existing servicing, which could potentially be worsened through the introduction of additional servicing on street.

4.5.4 - The County Council are not supportive of the introduction of taxis on Fitzroy Street and Burleigh Street. CCC have previously suggested that use of the service areas (Burleigh Place) by taxis out of hours may be an acceptable way of allowing taxis into the area without allowing access into the pedestrianised area of Fitzroy Street and Burleigh Street. However, this doesn't appear to have been carried through into the SPD.

CCC HIGHWAYS COMMENTS Planning policy context
1.4 "Be focused on providing access by sustainable modes of transport including improvements for pedestrians and cyclists such as a managed cycle parking facility, and with no increase in car parking above current levels";
* How will this be achieved by removal of the current, convenient on-street cycle parking just outside the shops and reintroduction of conflict with motor vehicles on
Fitzroy Street and Burleigh Street?

"Improve the public realm along Fitzroy Street and Burleigh Street, by removing unnecessary
signage and street furniture, and using a simple and durable palette of materials";
* How will this be achieved if more traffic regulation and enforcement would be required?
* How will this be maintained in the long term, given current financial constraints?

Parking
2.2.4 - The site is within a Controlled Parking Zone (CPZ) which means on street parking is restricted at certain times of day.
* The area is also subject to a Residents' Parking Scheme. Residents of any
subsequent development would not be eligible for Residents' Permits.

Cycle routes and parking
2.2.12 - The location and amount of cycle parking will need to be carefully reviewed as part of this SPD.
* This statement should include the stated intention that this must be as, or more, convenient to use than that which currently exists.

2.7.5 - Movement and access: Adapt and redevelop the service areas to the Grafton
Shopping centre to better integrate the shopping centre into its context.
* Should this not also include the aspiration to provide effective, efficient servicing?

Review the car parking requirement and redevelop the Grafton West Car Park.
* Surely the redevelopment should be a provisional aspiration if demonstrated to be appropriate?

4.2.18 Longer-term proposals for servicing assume that normal retail and leisure units could be serviced from key primary streets based on an agreed management strategy including core servicing hours and restrictions on maximum sizes of vehicle as appropriate.
* The reintroduction of motor vehicles, or increased servicing utilising Fitzroy Street or
Burleigh Street is seen as a retrograde step. These streets were pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Surely the aspiration should be to remove the conflict between pedestrians, cyclists and servicing vehicles, rather than manage an increased amount?

Car parking - residential and office uses
4.2.24 Cambridge City Council's car parking standards are expressed as maximum
standards in line with national guidance
* This is no longer National Guidance - please refer to the NPPF
* Residents will not have access to Residents' Permits (see above)

4.2.24 Subject to further discussion and liaison with the County Council, there is an aspiration to create an integrated approach to movement on Fitzroy Street and Burleigh Street. This could involve improved management of servicing where this occurs on street, potential for the introduction of out of hours taxi operation, cycling and other streetscape improvements.
* Servicing activity on Fitzroy Street would take place out of hours and would require enforcement, potentially utilising ANPR cameras.
* Provision for a contraflow cycle lane on Fitzroy Street to accommodate cyclists throughout the day (24/7, not restricted access as currently) is also key.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.
* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.
* Figure 41 shows a pedestrian crossing in the junction of Burleigh Street with East
Road. If Burleigh Street is open to vehicular traffic, this is undeliverable on several levels, not least of which is highway safety.
* Provision of a segregated cycleway in the pedestrian area is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space reserved for their use.

4.5.3 Subject to further assessment, proposals should demonstrate an integrated approach to cyclist and pedestrian movement including the creation of defined footways and shared surfaces. The pavements should accommodate primary pedestrian movements and accommodate other functions such as al-fresco eating and occasional market stalls. The re- instated carriageways could have the character of a shared surface, enabling informal negotiation between users including pedestrians and cyclists.

* How do you have both footways and shared surfaces? A scheme can either be shared surface/space or segregated, not both.

* Provision of segregation in what is now a pedestrianised is not seen as beneficial.
Identification of a segregated vehicular route will be interpreted as priority space

reserved for their use. Pedestrians will be expected to keep to the footways as identified. This downgrades the position of the pedestrian within the user hierarchy as defined in Manual for Streets, in an area where place should be dominant over transport function.

4.5.4 It is proposed, subject to more detailed design and assessment that taxis could operate on Fitzroy Street and Burleigh Street outside of core hours. The delivery of these public realm improvements should be linked to the adjacent development proposals.
* As previously stated the Highway Authority does not support this approach, this is not regarded as a desirable aspiration, but a retrograde step. These streets were
pedestrianised for good reason.

* Modification of the Traffic Regulation Order governing the streets concerned is a process is outside the planning process and so may not be deliverable.