Monday 2 November 2020

LTN 1/20, Merton Council FAQ and the Planning Application Process for Bishopsford Road Bridge

On 22nd October Merton Council's Planning Committee approved the proposals for Bishopsford Road  (Mitcham) Bridge. Like many local groups and residents we have concerns about the design and layout and whilst we want a re-constructed bridge as swiftly as possible we also think what is built should be fit for purpose far into the future, and meet the Council's own policies to tackle the Climate Emergency and promote active travel. 

Many of our concerns stem from the ways in which the designs don't meet the Department for Transport issues Local Traffic Notes (LTNs) to guide Council’s designs.  The latest of these is LTN 1/20 which was issued in July 2020 and covers Cycle Infrastructure Design. (Local Traffic Notes are different to 'Low Traffic Neighbourhoods / LTNs.) We believe the LTN 1/20 Guidance was misrepresented to the Planning Committee. 

The Planning Committee were recommended to approve a shared-use pavement on the bridge based on a quotation from a section of LTN 1/20 which specifically relates to Motor Traffic Free areas and therefore is not applicable to this road bridge design. A follow up Q&A on Merton’s website, regarding the Planning Approval, claims that guidance allows shared-use on bridges if there isn’t sufficient space. LTN 1/20 makes clear that this applies not to road bridges but to Motor Traffic Free bridges.  

These serious misrepresentations of LTN 1/20 are putting the Council in the position of promoting an installation likely to endanger all users of the bridge.  

This can be relatively easily resolved by slight rearrangement of space to give two dedicated cycle lanes and a pedestrian pavement which conforms with the ambitions expressed in the Planning Application's Design and Access statement and fundamentally does not go against the carefully researched guidance of Local Transport Note 1/20.  

MCC's response to the Council's Q&A 

Last week a series of Questions and Answers were published on Merton’s Council  website to justify Committee Approval of the design for Bishopsford Road Bridge.  

Question: I have been told that the bridge doesn’t meet cycling design regulations published by the Government in July 2020  

LB Merton Answer: It does. In summary, the new guidance recognises that shared surfaces between pedestrians and cyclists aren’t ideal but can be used where there isn’t enough space, such as on bridges and underpasses. Section 6.3 of guidance sets out how to design a shared surface and Merton’s design fully complies with this.  

MCC's Response: 

The LTN 1/20 section that covers shared-use is Section 6.5. The quoted Section 6.3 relates to Light Segregation and is therefore inappropriate for shared-use.   

Section 10.8 covers bridges and underpasses, but these are bridges and underpasses that are limited to pedestrian and cycle use and are Motor Traffic Free.  

Section 6.5 whole-heartedly discourages shared-use on pavements in built up areas. However says if it must be done it should be ‘well designed’ 

Table 6.3 (as opposed to Section 6.3) comes under sub clause 6.5.7 and gives recommended minimum widths of shared use routes carrying up to 300 pedestrians per hour with up to 300 cyclists per hour at 3.0 metres and with over 300 cyclists 4.5 metres.  

Where pedestrian flows are higher, it says greater widths should be used to reduce conflict.   

In the Officers Report to the Planning Committee that recommended approval    

The Report’s Item 8.9.14 states ‘Members should consider the guidance note from DfT Local Transport Note 01/20 which states that “A fully shared surface is preferable to creating sub-standard widths for both pedestrians and cyclists where the available width is 3.0m or less”   

This quotation from LTN 1/20 sub-clause 8.2.8 is from Section 8 which is devoted entirely to Motor Traffic Free Routes and therefore is not the context for this bridge.  

If the Officers Report to Committee had been minded to include sub clause 15.2.20 which refers to the edges and verges of such off-road paths, the Committee would have understood that  “Vertical features such as hedges and walls reduce the useable width, so ideally a mown grass verge or low, slow growing plants should be provided for 1.0m immediately next to the path”.   

A road bridge is in a different context being shared-use next to motor traffic but having a parapet beside it will in the same way reduce the useable width.   

Should the design of the bridge have a verge of one metre between the shared-use and a parapet?  

An answer to this is available in Local Transport Note 1/12 which was specifically on shared-use and took it for granted. The attitude has altered with the publication of LTN 1/20 and LTN 1/12 was withdrawn.  

However cyclists and pedestrians haven’t altered and they retain the same dimensional characteristics as under LTN 1/12. If a shared-use pavement is to be forced on this bridge and it is to be ‘well designed’ and safely designed then the dimensional implications for interaction between pedestrians and cyclists need accommodating. A very clear and universal diagram was available in LTN 1/12 and is highly relevant if shared-use is, against guidance, to be used.  

This involves the proximity to vertical elements and the effect these have on cyclists, in particular. But in the melée of unsegregated shared-use vertical elements become a safety issue for both cyclists and pedestrians. Both pedestrians and cyclists are vulnerable if unbalanced by being squeezed over a pavement edge into the path of A217 motor traffic on account of the pavement being too narrow. This applies to the bridge approved by the Planning Committee. It can be concluded that this is a dangerous arrangement that is likely to get more dangerous in future years under a Council Policy promoting Active Travel.  

With regard to carriageway widths this is covered under Section 6.1.1 in LTN 1/20 where reduction in carriageway width is encouraged.  This contrasts with Section 6.5 where shared-use on pavements in built-up areas are actively discouraged.   

The safe solution to this bridge and only way to satisfy the dimensional restraints is to reduce the carriageway width and have two dedicated cycle lanes and a pedestrian pavement. For pedestrians, the bridge parapet does not increase the pavement’s effective width so separation of cyclists and pedestrians is the answer.