2.1 The proposal for HMO's is too generous compared to normal residential standards. A fifth of HMO's are not let to students and the ratio of bedrooms to cars is is nearer 1 to 1 than 2 to 1. Fairer standard for HMO's would be 1 car per bedroom up to 2 bedrooms, as for residential, then 1 car for every 2 bedrooms.

The proposals not to set a standard for Purpose Built Student Accommodation leaves a potentially large loophole and is not satisfactory. The standard should be set as per HMO's (treating each flat 'cluster' as a single HMO for parking purposes) but with permitted exceptions on a case by case basis. This would allow developments with convincing on-site management of zero car leases to be accepted should the current experiment with such an arrangement at Union Court ('Alumno') prove successful.


2.4 b) The proposed Unilateral Undertaking on some developments, to relinquish the right to Residents' permits, may help mitigate daytime parking pressures for existing residents in some areas eg Town Centres. However the major pressure in most areas is overnight resident parking. RPZ's do not operate at evenings or overnight. The proposal is therefore of limited value. All applications involving additional on-street parking, whether covering an RPZ in whole, in part or not at all should require there to be a full 100 degree parking survey and the planning focus should be on available overnight capacity.

2.7 Make it clearer that the unallocated spaces required for developments of more than 10 units are additional to the minimum off-street parking space requirements per dwelling.

2.11 This paragraph refers to allocated, i.e. on plot, parking spaces that have different dimensions to those specified in the methodology for parking surveys referred to in para 2.8 on the same page. Therefore, for avoidance of doubt, para 2.11 should be amended as follows:

In line with emerging WCC advice, parking space dimensions FOR ALLOCATED PARKING ON-PLOT required by this SPD are greater than those that have been sought in the past. The dimensions below are minimum requirements:

NON-RESIDENTIAL PARKING

4.3
A3 & A4 Evidence base suggests the standards for these two categories are too generous and should be tightened in line with neighbouring authorities to reflect growing car ownership and on-street parking stress during evenings near such high customer volume commercial premises.

B1c. Evidence base suggests there has been a small loosening of standards for this category. But the ratio quoted for Low access standards in 2007 at 1/40 is identical to the new proposed standard. Is there an error in text or in the two ratios given ?

Cycling Standards
Evidence and policy both seem to point to the need to tighten cycling standards for A3, A4 , B1, B8 and D1 medical establishments, not leave them unchanged.

APPENDIX A
I support Mr Richmond's responses to this section viz
1. The figures given in the results tables shown in the consultation response
document require correction.
2. The parking stress figures for streets B and C for not in a RPZ in the
Parking Standards Document are incorrect.
3. The calculation of the number of spaces is overstated and should be factored down to 90% to reflect practical capacity (see 2005 Arup study). Parking stress should then be re-calculated.
4. Parking demand from residential developments approved, but not yet constructed/occupied should be added to the total measured demand on the basis of the Parking Standards Document