Parking standards for London

for retail, leisure,

mixed use development
and other uses

Harrison Webb
1 Hillside Cottages, Blackheath Lane
Blackheath, Guildford
Surrey, GU4 8QU

tel and fax: 01483 892137

david_a.harrison@which.net

August 2002

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Contents
Page No.

1: Introduction
Conduct of the study 5
Contents of this report 7

2: External policy consistency

PPG 13: Transport 9
RPG 3: London Planning Guidance 13
PPG 6: Town Centres and Retail Developments 16
RPG 9: Regional Planning Guidance for the South East 16
Changes to the planning system 17

3: Policy consistency within London

Pan-London acceptability 21
The proposed approach to retail developments 23
Proposed retail car parking standards 28
The proposed approach to leisure developments 30
Proposed leisure car parking standards 32
Transport Assessments, parking standards and Travel Plans 34
Operational parking 35
Parking for disabled people 35
Cycle parking 35
Coach parking 35

4: Mixed use developments

Technical approach 37

5: Parking Standards for other uses

A2 Financial and professional services 39
A3 Food and drink 39
B8 Storage and distribution 41
C1 Hotels 41
C2 Residential institutions 42
D1 Non-residential institutions 42
Parking for disabled people 44
Cycle parking 44

6: Conclusions and recommendations

Conclusions 45
Recommendations 47

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Appendix A:
Consultation findings 51

Appendix B:
Developer contributions 59

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1: Introduction
This study was undertaken to inform the Mayor’s London Plan (Spatial
Development Strategy (SDS)) about an appropriate approach for applying parking
standards to new retail and leisure developments and mixed use development in
London.

The London Plan will guide the development of London for the next 15-20 years. It
seeks to integrate economic and social development and to improve the
environment of Greater London. The aim of the Plan is to accommodate the
projected growth of population and prosperity in a way that addresses London’s
current problems. London’s population has already increased by almost 600,000
since 1989 and it is projected that London will grow by a further 700,000 by 2016.
This rapid rise in London’s population is expected to be matched by a
corresponding growth in employment provided infrastructure shortages are
successfully dealt with. The guiding policies for the London Plan seek to
accommodate this growth sustainably and to ensure the availability of the facilities
and services needed to support growth.

Key transport policies focus on using the public transport system as the framework
for new development. Development, especially that with high trip generating
characteristics, should be located where public transport accessibility is high and
where there is adequate system capacity. Parking provision for such development
should be limited appropriately, to maximise the use of alternatives to the car,
minimise car use and reduce congestion. Development should be designed to
ensure easy and safe access for pedestrians, cyclists and public transport users.

The study sets out an approach to parking standards for retail, leisure and mixed
use development that can be used by the London Plan to provide guidance for the
Boroughs. Boroughs will then need to interpret this guidance locally in setting
parking standards in their Unitary Development Plans (UDPs).

This introductory section of the report describes the conduct of the study and the
layout of the report.

Conduct of the study

1.1 The study was commissioned by the Greater London Authority (GLA) on 21
September 2001. The commencement date was 24 September 2001. Key
milestones were:

 an Issues Paper by the end of October

 a draft Final Report by the end of November

 a Final Report by the end of December.

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1.2 The work required was described in the GLA Brief issued on 31 August with
the letter of invitation to tender. We submitted our proposal on 12
September. Clarification of some aspects of the proposal were agreed by
the GLA and ourselves and included as Annex 1 to the Brief on 21
September.

1.3 The GLA selected a Steering Group to manage the study. The inaugural
meeting took place on 27 September 2001. Meetings subsequently took
place on:

 19 October

 21 November

 14 December

 15 February 2002

 14 March 2002.

1.4 The Issues Paper was submitted on 31 October. It set out a proposed
basis for:

 achieving external consistency with Government policies

 achieving internal consistency within Greater London

 progressing the study to completion.

The Issues Paper was formally accepted on 01 November and forms the
basis for this report.

1.5 It was confirmed on 06 November that the SDS Editorial Team was also
content with the proposed approach. We noted that they were keen to
ensure that the policy stance represented by the proposals conformed with
the Mayor’s evolving position on planning decisions in London.

1.6 In the course of the study we were supplied with:

 Public Transport Accessibility Levels (PTALs) maps produced by

Transport for London (TfL)

 the GLA’s detailed objections to a number of Unitary Development

Plans (UDPs) since 03 July 2000

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  a schedule of currently adopted parking standards for each London
Borough prepared by Transport for London (TfL).

1.7 Reference has also been made to trip rate databases (eg TRICS and
TRAVL) and to the Transport Appeals Journal published quarterly by
Harrison Webb. The Journal contains detailed abstracts of all transport-
related planning appeals decisions in England, Scotland, Wales and
Northern Ireland.

1.8 The study has been informed by comments from officers of a number of
London Boroughs on the proposals and approach. A brief consultation
exercise took place in January 2002 and is documented in Appendix A.

1.9 Work to develop parking standards for other uses, excluding employment
generating and residential was commissioned by the GLA on 7 March 2002.
The purpose was to provide material and advice that could be used by the
Mayor’s London Plan to provide guidance for the Boroughs on car parking
standards for other uses (excluding employment generating and residential)
not covered by the initial commission. London guidance on parking
standards for employment generating uses was initially set out in RPG 3,
but has since been modified by RPG 9. PPG 3 and RPG 9 set out national
and regional guidance on parking provision for residential uses.

Contents of this report

1.10 Section 2 describes the relationship between the Government’s Planning
Policy Guidance (PPG) and our proposed approach for London. Section 3
proposes an overall approach to setting and using parking standards across
London that seeks to reflect the widely differing transport and land use
characteristics of London boroughs. Section 4 sets out a preferred
approach for mixed use developments. Section 5 provides guidance for a
variety of other uses.

1.11 Section 6 sets out conclusions and recommendations.

1.12 Appendix A documents the findings of the consultation exercise.

1.13 Appendix B sets out proposals in respect of developer contributions.

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2: External policy consistency
The Mayor’s first priority is to create a world class transport system for London.
This will involve investment in major increases in the capacity of the capital’s public
transport system that will require funding from the Government. The Government
seeks compliance with its national transport policies when distributing funding.

London is the powerhouse of the UK economy and Parliament has restored

democratic accountability by creating an authority and the office of a directly
elected Mayor. It is important that national policy is interpreted locally in a way that
reflects London’s special needs and characteristics and accommodates projected
growth. But it remains important that transport planning policies for London can be
shown to be compatible with national policies to ensure a continuing supply of
capital funding.

This section of the report considers how policy on parking standards for London
can conform with the Government’s guidance in PPG 13 (and PPG 6) and Regional
Planning Guidance (RPG) 3 and 9. Note is also taken of possible changes to the
planning system that might result from the Government’s Planning Green Paper.

PPG 13: Transport

2.1 PPG 13 sets out the Government’s position on the relationship between the
location of new development and its sustainability. Development should
preferably be located where it can reduce the need to travel and where it is
safer and easier for people to access jobs, shopping, services and leisure
opportunities by public transport, walking and cycling. In this context, PPG
13 has a lot to say about parking standards for new development, reflecting
the fact that car parking has a major influence on transport mode choice:

 levels of parking at new development should promote sustainable

transport choices

 developers generally should not be required to provide more spaces

than they themselves wish

 shared use of public and private parking should be encouraged

where peak levels of parking demand do not coincide

 parking standards should not create perverse incentives to develop

away from town centres

 authorities should be cautious in prescribing different levels of

parking between town centres and peripheral locations

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  good quality secure parking is essential to the economic welfare of
town centres and to enable retail and leisure uses to flourish
(reference PPG 6 Town Centres and Retail Developments)

 designated spaces should be provided for disabled people

 on-street parking controls should be introduced adjacent to new

development where necessary to control displacement of parking

 safe and secure cycle parking should be provided in accordance

with local policies and good practice

 appropriate provision for motorcycle parking should be considered

 maximum parking standards should be set for broad classes of

development

 the levels of parking set out in PPG 13 (Annex D) should be applied

as a maximum throughout England, although more rigorous
standards may be set locally.

2.2 There is an element of policy tension in one aspect of PPG 13. Over-
arching Government policy is to locate new development where non-car
accessibility is good or can be made good. This locational policy
acknowledges that accessibility varies spatially. This means that mode
choice must vary spatially. Yet PPG 13 seeks national consistency in
parking provision and expresses a degree of concern about spatial
variation. However, PPG 13’s maximum parking standards are not relevant
in Central London (eg Westminster) where good quality alternatives to the
car mean that much tougher standards can be adopted. Elsewhere, new
development cannot always be ideally located; if it could there would be no
need for the sequential testing procedures set out in Government guidance.
Variation in accessibility and, hence, mode choice should therefore be
reflected in variation in parking provision at new development. Our
proposed approach embodies this logic.

2.3 Reduced parking provision where there are good quality alternatives to the
private car avoids unnecessary land take and reinforces the mode choice
message. The residual demand for car parking should be accommodated
on-site (ie within the development) to prevent the damage to amenity (and
other adverse impacts) caused by parking overspill in adjacent streets.
Overspill is not automatic but complementary on-street parking controls
may be necessary to reinforce overall parking management. These will not
necessarily be the total responsibility of the developer as they may also
help meet other parking needs and priorities.

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2.4 This approach is effectively already in place in many places. Private non-
residential parking in town centres and/or conservation areas is deliberately
restricted to limit adverse traffic impacts, improve amenity and possibly to
allow pedestrianisation. The great majority of town centre retail and leisure
premises do not have dedicated car parking. Public or shared private
parking in major multi-storey car parks generally provides for town centre
car parking demand.

2.5 This approach to spatial variation in parking provision is compatible with

RPG 9 (see below) and a similar approach has recently been
recommended by the Scottish Office.

2.6 As the Mayor’s Transport Strategy (July 2001) confirms, there is

considerable variation in public transport accessibility across the 33 London
authorities. Highway capacity is constrained; this is reflected in policies that
adopt the following weekday traffic targets for 2011:

 an absolute reduction of 15% in Central London

 zero growth across the rest of Inner London

 reducing growth in Outer London by a third, with the aim of

achieving zero growth in Outer London town centres.

(reference: The Mayor’s Transport Strategy, Proposal 4G.12)

2.7 These objectives are not set in the context of economic stagnation or
decline. They are associated with long term ambitions for major growth in
the capital’s population and jobs. Whilst congestion charging and related
policies are the means of restraining traffic associated with existing
development (the source of the bulk of travel demand), it is vital that the
new development that will deliver economic growth does not undermine
these overall objectives. Thus car parking at new development should:

 be compatible with viable development, whilst…

 discouraging avoidable car use, and…

 encouraging the use of sustainable transport choices.

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2.8 This implies taking account of the spatial variation in non-car accessibility in
a way that reflects the Mayor’s overall ambitions for managing traffic levels
in different parts of the capital. If too much parking provision is made, there
will be little incentive to use other means of transport because the car
remains the preferred means for most people, including the disabled. If too
little parking provision is made relative to access by other means then the
development will not achieve the accessibility necessary for viability and
adverse parking displacement effects will take place.

2.9 In Central London, the planned £5 congestion charge and other measures
seek to tackle congestion and reduce traffic levels. In Outer London, where
car use dominates, the Mayor aims to improve journey time reliability for car
users and minimise traffic growth whilst increasing travel choice. To
complement this, locational policies seek to direct development to
appropriate sites with good public transport access in order to restrain car
use. Thus the whole transport policy edifice for London is predicated on
policies that seek to direct development to locations with good accessibility
by non-car modes, that strategically restrain car use and contribute to
growth targets by ensuring that new development is viable. Car parking
standards for new development must reflect similar priorities and therefore
must retain a spatial dimension.

2.10 Reconciling this stance with PPG 13 involves the following explanations.

 Locational policies for new development are paramount (and will not
be influenced by any significant future change in London’s road
network) and should be applied to prevent perverse incentives to
develop in unsuitable locations.

 Parking standards are subservient to this over-riding policy but must

take account of variation in non-car accessibility to maximise
sustainability whilst ensuring that economic growth will take place
as planned.

 Any proposed parking standards must be at least broadly

compatible with (if not more restrictive than) the maximum
standards set out in Annex D of PPG 13 (ie for retail, cinemas,
conference centres, other assembly and leisure uses, and stadia).

2.11 The retail standards in PPG 13 can be shown by objective data (eg TRICS)
analysis to be compatible with relatively unfettered car use. They would be
the starting point for a process of progressive reduction where justified.
PPG 13 states that “…opportunities exist to reduce levels of parking for
developments in locations with good access by non-car modes…”.

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2.12 Leisure use standards traditionally vary according to location. Preferred
central urban locations can often exploit adjacent public parking.

2.13 The standards involved are:

Use National Threshold

maximum above which
parking standard
standard applicable
food retail 1 space per 14m2gfa 1000 m2gfa
non-food retail 1 space per 20m2gfa 1000 m2gfa
cinemas, conference 1 space per 5 seats 1000 m2gfa
facilities
other assembly and leisure 1 space per 22m2gfa 1000 m2gfa
stadia 1 space per 15 seats 1500 seats
(source: Annex D, PPG 13, DETR, March 2001)

RPG 3: London Planning Guidance

2.14 RPG 3 was issued in 1996 and included parking standards for car parking
at employment-generating development. These standards were very
restrictive, even for Outer London and caused great concern in such
Boroughs. The standards were:

Location Max. of 1 space per x m2gfa

Central London 1,000 – 1,500
Inner London 600 – 1,000
Outer London 300 – 600
(source: RPG 3, 1996)

2.15 Relevant national data (eg TRICS) shows that unfettered car use would
indicate standards of 1 space per 30 - 35m2gfa for offices and business
parks respectively (PPG 13 suggests 1 to 30m 2gfa). So even in Outer
London where car use dominates, a reduction factor of at least 10 was
implied by RPG 3. Just outside London, car use also generally dominates
and maximum parking standards are typically based on observed
unfettered car use, albeit with scope for reductions in certain circumstances
to encourage use of non-car modes.

2.16 RPG 3 thus introduced a dramatic boundary effect that was not reflected in
travel attitudes or behaviour. The lower limit in RPG 3 has subsequently
been revised down from 1 space per 300m2gfa to 1 space per 100m2gfa to
be compatible with RPG 9 (see below) and to reduce this boundary effect.
This standard still implies a reduction factor of 3 relative to unfettered use.

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2.17 The impact of this discontinuity in standards can be illustrated by an
example. If we assume that average employment densities in offices are,
say 1 per 21m2gfa (from SERPLAN) then 10,000m2gfa of office
development would accommodate about 480 employees. The implied
mode choices for varying levels of parking standard are as follows.

Parking standard Cars

1 space per accommodated
x m2gfa per 100
employees
20 104
25 83
30 69
35 60
40 52
100 21

2.18 The national average proportion of car use for the journey to work is 70%.
However, London is very different. In Central London, only 13% commuted
by car whereas in Outer London the proportion was close to the national
average at 68%. The overall average for London is 43%. The source of
this data is the Labour Force Survey for 2000.

2.19 This means that in Outer London and outside London and the other major
conurbations, unfettered car use is likely to be represented by between 70
and 80% of commuting trips being by car. Research into Travel Plan
effectiveness suggests that a major effort is required to reduce car use for
commuting down to 60% from such levels and that it may be very difficult to
improve further on this achievement, even in what are thought to be highly
accessible locations.

2.20 Thus the PPG 13 standard for offices of 1 space per 30m 2gfa represents a
very modest reduction on unfettered car use. The maximum standard of 1
space per 100m2gfa set out in RPG 3 (modified) and RPG 9 represents a
dramatic reduction in car use beyond that normally achieved by Travel
Plans, except in Central London and any other areas with similar public
transport accessibility. Manipulation of car occupancy assumptions does
not significantly change this conclusion.

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2.21 We considered whether retail and leisure standards should be as restrictive
as the employment standards set out in RPG 3/RPG 9. We concluded they
should not be. It appears from PPG 13 that the Government believes that
the viability of retail development at least could be threatened by too
restrictive a standard and that this could jeopardise town centre
regeneration. Other reasons for not making these standards as restrictive
as the employment ones are set out below.

2.22 One supporting argument is that the journey to work is the prime cause of
peak period congestion. Congestion greatly increases pollution per vehicle
kilometre. It is therefore appropriate to bear down on peak period travel
demand. Furthermore, London’s public transport system is heavily
influenced by peak period commuting patterns. Retail and leisure travel is
substantially off-peak and, in the latter case, often in the evening.
Congestion is typically reduced at such times in Outer London locations and
therefore environmental concerns could be somewhat diluted, although off-
peak congestion is increasing, including at weekends. Furthermore, public
transport service provision reduces in the evening and there is greater
reliance on the car for personal security reasons. The available supply of
public town centre parking increases in the evening.

2.23 A second supporting argument is that Government guidance acknowledges

that town centre regeneration and viability is heavily dependent on an
adequate supply of short stay car parking. If this supply is judged to be
currently inadequate then additional development-related provision is one
solution, as suggested in PPG 13. This should preferably be on the basis
of allowing use by the general public (and controlled by charging if
necessary with refunds for retail/leisure development users). Government
guidance does not support applying this approach to car-based commuting.
PPGs 6 and 13, guidance on Local Transport Plans and the Mayor’s
Transport Strategy all stress the need for town centre Parking Plans
embodying these principles.

2.24 A third supporting argument for separating retail and leisure parking
standards from employment standards is that the former uses would be
expected, where possible, to share short stay public car parking in town
centres (reference PPG 6: Town Centres and Retail Developments,
endorsed in PPG 13). Employment standards relate to long stay parking
that would normally be discouraged in central areas.

2.25 It is therefore reasonable not to use the employment standards set out in
RPG 3 and RPG 9 (see below) as the starting point for retail and leisure
standards.

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PPG 6: Town Centres and Retail Developments
2.26 PPG 6 (published by DoE in June 1996) provides planning policy guidance
on town centres and retail developments. Local authorities should produce
a comprehensive strategy and a set of policies for the provision and
management of parking designed to reinforce the attractiveness and
competitiveness of town centres and to support the locational policies in
PPG 13. The emphasis is on parking that serves the centre as a whole
rather than dedicated parking for individual developments. Local authorities
are advised to promote the provision of car parks that are shared between
shoppers and others needing short-term parking and to discourage long-
term parking by commuters.

2.27 PPG 6 introduced the sequential approach to site selection for retail and
other key town centre uses which attract a lot of people, including
entertainment and leisure. Adopting a sequential approach means that first
preference should be for town centre sites, followed by edge-of-centre sites,
district and local centres and only then out-of-centre sites in locations that
are accessible by a choice of means of transport. Developers are
encouraged to be more flexible about the format, design and scale of the
development and the amount of car parking, tailoring these to fit the local
circumstances.

2.28 PPG 6 was endorsed, added to and clarified by Planning Minister Richard
Caborn in his Ministerial Statement of 11 February 1999. The Ministerial
Statement made it clear that planning applications for shopping and leisure
development (including extensions) in edge-of-centre or out-of-centre
locations should be required to demonstrate both the need for additional
facilities and that a sequential approach had been applied in site selection.

RPG 9: Regional Planning Guidance for the South East

2.29 RPG 9 was the delivery mechanism for modifications to the RPG 3
employment standards for London. Thus the reasoning adopted above for
separating employment standards from retail and leisure standards in the
context of RPG 3 applies equally well to RPG 9.

2.30 RPG 9 differs from PPG 13 by referring to the need to consider varying
parking provision, generally implying reductions in provision to encourage
use of non-car modes. Variation should reflect the state of the local
economy, the size of a settlement and public transport accessibility, the last
two being linked. So the spatial variation principle is recognised. RPG 9
notes the need to avoid perverse effects when applying this approach,
echoing PPG 13 to achieve partial consistency.

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Changes to the planning system
2.31 The Government wishes to make the planning system more efficient as part
of the process of modernising public services. It published a Green Paper
dealing with reform of the planning system in December 2001.

2.32 The Government has concluded that the existing planning system is
“complex, remote, hard to understand and difficult to access”. The plan-led
system is multi-layered and often out-of-date. National guidance is long
and mixes policy principles with good practice. Planning rules affect
different land uses in different ways. The appeals system is obscure. The
consultative processes involved are extensive but still fail to engage the
public. Overall, the process is too slow.

2.33 The changes the Government seeks include:

 abolishing structure, local and unitary development plans

 replacing the multi-layered system with a single layer of Local

Development Frameworks (LDFs) consisting of:

- a statement of core policies concerning the promotion and

control of development

- detailed action plans for smaller areas of change, such as

urban extensions, town centres and neighbourhoods

- a map showing areas of change and existing designations

 LDFs will connect up with the local Community Strategy which

should consist of:

- a long term vision for an area

- an action plan identifying shorter-term options that will

contribute to the long term vision

- a shared commitment between the community, private

sector and the local authority to implement the action plan
and proposals for doing so

- arrangements for monitoring implementation and periodical

reviews

 business planning zones will allow planning controls to be lifted if

they are unnecessary.

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2.34 It appears that parking standards will find a home in the LDF statement of
core policies as these will include criteria-based policies that will form the
basis for development control.

2.35 The basis for setting parking standards will remain national guidance.
However, the Government now thinks that PPGs are too long, too
prescriptive and stifle appropriate local flexibility. This chimes with our
concerns about some aspects of PPG 13 expressed in paragraph 2.2
above. The Government proposes to review planning guidance and more
clearly distinguish between policy guidance and practical application. PPG
3: Housing is considered a good model; it is supplemented by five good
practice guides. PPG 13 is not included in the early review programme but
PPG 6 is.

2.36 The Government is also currently considering reform of the Use Classes
Order. A consultation paper has been issued. This is intended to respond
to modern retailing, leisure and employment practices and considers re-
organising the allocation of Use Classes. This affects “change of use”
issues but need not greatly disturb parking standards. Parking standards
have traditionally disaggregated Use Classes because the travel
characteristics of development categories within Use Classes vary
considerably.

2.37 The Government has also issued a consultation paper on reforming

planning obligations as a daughter document to the Planning Green Paper.
The aim is to make the process more transparent. The law will be changed
to make sure that agreements and undertakings must be entered on the
planning register rather than added as a matter of good practice.

2.38 The daughter document refers to the use of planning obligations to :

 enhance the quality of development and the wider environment

 ensure a positive contribution to sustainable development

 provide social, economic and environmental benefits to the

community

 provide an increasing supply of affordable housing

 provide public spaces

 provide the facilities and infrastructure to accommodate growth.

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2.39 Previously, if a developer could not meet the minimum parking required by
local authority standards on a development site, the authority could require
a payment (a commuted sum) based on the cost of providing parking
spaces away from the site to make up the deficit. However, with the move
to maximum standards, PPG 13 has confirmed the demise of commuted
parking payments.

2.40 Commuted parking payments sat alongside developer contributions made

under section 106 of the Town and Country Planning Act 1990. Circular
1/97 advises that developer contributions should be relevant to planning,
directly related to the development, reasonable and sought only where they
are necessary to make the proposed development acceptable in land use
planning terms (the compliance tests). Planning obligations may relate to
matters other than those covered by a planning permission and associated
conditions.

2.41 The switch from minimum to maximum parking standards undermined the
basis for commuted parking sums. PPG 13 is clear that there is no basis
for seeking commuted payments in lieu of parking that is not being provided
on-site. Planning obligations should be used to improve public transport,
walking and cycling where such measures would be likely to influence travel
to the site either individually or as part of a package of measures.
Developers are expected to contribute more for improving non-car
accessibility where the site is located away from town centres and transport
interchanges (once again acknowledging spatial variation).

2.42 A further consideration relates to the nature of Local Transport Plans

(LTPs) and, in London, Local Implementation Plans (LIPs). The linkage
between LTP/LIP programmes and developer contributions is confirmed in
PPG 13 and The 10 Year Plan: Transport 2000 (DETR, July 2000).
Guidance on Full Local Transport Plans issued in March 2000 states:

 a good LTP will maximise the contribution of the private sector, both
as a source of funds and as a provider of services

 local authorities should work with retailers and operators of leisure

facilities to identify alternative means of access in place of car
usage (where appropriate, authorities should look to the private
sector to fund schemes).

2.43 LTP/LIP programmes include specific measures that are fully designed and
costed. They also contain less well developed programmes that may also
be particularly dependent on private sector funding.

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2.44 In previous commissions we have advocated a two-strand approach to
transport-related developer contributions. A summary of our findings is
included as Appendix B.

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3: Policy consistency within London
This section of the report recognises the need for policy consistency across all 33
London authorities when applying new guidance. This is not a trivial task.
Tensions between Inner and Outer Boroughs were caused by RPG 3’s treatment of
employment parking standards and, possibly, by LPAC’s previous guidance. The
Outer authorities argued that the guidance has been too Central London-orientated
and that non-car accessibility in their areas is much more reminiscent of authorities
outside London. The previous guidance was perceived to threaten their ability to
compete for investment.

This section considers how retail and leisure standards can be presented in a way
that ought to be acceptable to all London authorities.

Pan-London acceptability
3.1 The starting point is that major new development should generally only be
located where public transport accessibility is good or excellent. This
should broadly cover all of London’s major town centres and most district
centres. The key to pan-London acceptance of up-dated standards lies in
the ability to show that:

 the wide variation in public transport and other non-car accessibility

can be taken into account

 changes in accessibility over time can be taken into account

 there is consistency in the treatment of these factors across London

 areas targeted for regeneration will be positively assisted but

without creating major exceptions

 the proposed maximum standards bear some relation to current

adopted standards.

It is therefore proposed that car parking standards for retail and leisure
development in London vary according to the level of public transport
accessibility.

3.2 A considerable amount is known about the variation in public transport

accessibility across London. The whole of London has been mapped by
TfL to show variation in PTALs.

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3.3 Although any assessment of non-car accessibility for a new development
must take account of local walk-in and cycle catchments, PTALs provide a
potentially consistent basis on which to base variation in parking provision
at new development. It is also a dynamic process that allows changes in
accessibility through public transport investment to be readily tracked. We
propose that PTALs are the basis for applying parking standards across
London but on a broad area-wide rather than site-specific basis. We also
note that because of the sheer scale and coverage of public transport
services in the central area, its PTAL 6 score is of a different nature to the
smaller PTAL 6 areas in outer London.

3.4 We recommend that TfL owns, maintains and up-dates such information
annually and provides a rolling forecast of PTALs to reflect imminent
accessibility changes resulting from the Mayor’s strategy. We are well
aware that PTALs calculations may have technical weaknesses in site-
specific applications and that they are sensitive to input assumptions.
However, the approach brings relative pan-London consistency and can be
applied in this context to whole areas (eg a town centre).

3.4 We also need to take some account of walk and cycle accessibility. Where
this is very good, there are opportunities for a substantial proportion of
employees and customers to walk and cycle, probably replacing some short
car trips. This should be reflected in reduced on-site parking provision at
new development. However, cycle and walking accessibility would not be a
continuous variable but a one step adjustment where appropriate. Its
significance would be assessed as part of a Transport Assessment. The
criteria in Government guidance provide a basis for judgement. Personal
security should be part of any assessment of walking accessibility and
security improvements (eg enhanced lighting) may be required as a
developer contribution.

3.5 Economic circumstances should also be taken into account. It is well-

known that vibrant economies can retain viability even if car use is further
constrained. Car users will trade increased personal inconvenience for the
better retail, amenity and cultural offer such economies can make.

3.6 Conversely, regeneration will not take place if the area is inaccessible.
Major improvements in public transport provision take time to implement
and will not be funded at all if there is no travel market. It is inevitable
therefore that initial regeneration will often be car-based in accessibility
terms. The way of ensuring eventual policy conformity is through phased
reductions in parking standards that are sensibly related to increasing non-
car accessibility. We do not think that economic viability needs to be
quantified as it is not a continuous variable in the process. There are
Government criteria to measure deprivation and related conditions.

22
3.7 Transport Assessments for new developments (which were introduced by
PPG 13) should provide an estimate of car parking demand within the
framework of maximising non-car travel and making the best use of
London’s public transport network. As explained below, PTALs-based
parking standards are the starting point for the iterative Transport
Assessment (TA) process. The process offers adequate opportunity for
refinement and adjustment to take account of local circumstances. This
could include detailed assessments of the overall PTAL value for a specific
development and its catchment.

The proposed approach to retail developments

3.8 Having established a basis for spatial variation in parking provision, we next
consider broad differences between retail and leisure developments. Social
change has resulted in some modern retail activity involving bulk
purchasing and the provision of shopping trolleys for transfers from shop to
car. This can allow better use of personal time, drives down prices and
offers greater choice. It is more likely than other types of shopping to
involve car use and the use of taxis and minicabs if a car is not available.
Home delivery and e-shopping will make some dent in this established
pattern of behaviour but it is likely that a successful retail economy will
continue to be car-orientated in some sectors.

3.9 The adverse impacts of the car dependency created by out-of-town retailing
can be minimised by siting such development in edge-of-centre locations.
This provides opportunities for town centre linked trips on foot, enhanced
transport choice, shared use of the parking provided (for the benefit of the
town centre as a whole rather than just the retail outlet) but keeps related
car traffic away from sensitive areas. Developers may provide shared
parking above the prescribed standard if it helps improve the adequacy of
the short stay town centre parking supply, as prescribed on PPGs 6 and 13.
However, developers would have to justify car-orientated retail development
in the terms set out in PPG 6 (eg Section 4). It is noted that a number of
leading car-orientated retailers modify their format to eliminate or greatly
reduce car parking in highly accessible locations.

3.10 Therefore, although major travel attractors should only be sited where
public transport accessibility is good or better (for example PTALs 4 - 6)
some account needs to be taken of inevitable and substantial car use
associated with some retail sectors. This suggests to us that the
appropriate parameters for establishing car parking at new retail
developments in London are:

 locations that are suitable for major travel attractors and those that
are unsuitable

23
  PTALs, to reflect variation in non-car accessibility

 levels of provision for unfettered car use, on which to base

reductions in parking provision at preferred locations

 economic vibrancy, as a second order adjustment

 walk and cycle accessibility, as another second order adjustment.

3.11 We concentrate on food and bulk shopping and retail parks because this
forms the majority of new retail development. We differentiate food
shopping by size because of well-established differences in travel
characteristics. Parking at retail parks should be assessed in accordance
with the above principles with account taken of individual elements and the
opportunity for a reduction in supply resulting from on-site linked trip-making
(see also Mixed use in Section 4). It is also envisaged that smaller
foodstores and supermarkets may be sited in district centres with PTALs of
3 or below.

3.12 Other forms of retail development should normally have no dedicated on-
site parking provision and should rely on the public parking supply, which
should be adequate in PPG 6 terms.

3.13 Planning applications for all major developments will normally be

accompanied by a Transport Assessment (TA) in accordance with PPG 13
and imminent Government guidance. TAs should consider how best to
provide the widest choice of travel options and, when this has been done,
finally consider the implications of car (and other) traffic. Parking standards
are an input to this process. They indicate broadly the degree of car
dependency that would be acceptable. Parking provision is also an output
of a TA as hourly traffic flow estimates allow hourly parking accumulation to
be calculated and peak demand identified. An iterative process may be
required to reconcile parking standards with expected car use.

3.14 We did not have the resources in this study to review the relationship
between parking provision, public transport accessibility and mode split.
We recommend that the GLA and TfL reviews existing survey data eg LATS
to provide a basis for varying car parking standards in line with PTAL
values.

24
3.15 We set out below indicative standards for accommodating parking at new
development under various circumstances. We base the approach on the
knowledge that the two extremes of the relationship between parking and
important variables are known. A great deal of existing town centre
development is viable without any dedicated on-site parking. This includes
new formats for what was previously car-orientated development. At the
other extreme, we understand the peak parking demands associated with
unfettered car use. The remaining task is to interpolate between these two
extremes to reflect intermediate circumstances where some car parking is
appropriate.

3.16 Standards relating to PTAL values of 1 equate to relatively unfettered car

use. Reference to a travel database such as TRICS and TRAVL provides
an indication of peak parking demand that reflects such levels of unfettered
car use. Using only a London-based dataset (eg TRAVL) could introduce a
risk of an unwanted external boundary effect. In fact, these databases
show broadly compatible trip rates for higher levels of car use. On this
basis, we consider the relevant standards are as follows:

retail land use parking standard for

unfettered car use
1 space per x m2gfa
smaller foodstore 30
(up to 500m2gfa)
food supermarket 18
(up to 2500m2rfa / c4000m2gfa)
food superstore 15
(over 2500m2rfa)
non-food warehouse 35
garden centre 25
local centre/shopping mall 30

3.17 These proposed standards for unfettered car use fit national as well as
London data, but are more restrictive than the indicative national standards
set out in PPG 13.

25
3.18 The starting point for the process for retail uses is therefore PTALs and
parking standards that are broadly derived from the benchmark standards
published in PPG 13. We use the term “broadly” because PPG 13 does not
provide enough disaggregation for a practical set of standards for
development control purposes nor does it set out an analytical basis for its
standards. We can demonstrate that PPG 13 standards reflect relatively
high car-dependency, certainly for retail uses, by reference to the TRICS
database and TRICS research. PPG 13’s standard of 1 space per 14m 2gfa
for food retailing would rarely impede car use. On the other hand, its
standard of 1 space per 20m2gfa for non-food retailing is, in our view,
unnecessarily generous. Unfettered demand would generally be
accommodated by a standard of 1 space per 25m 2 gfa or less.

3.19 It is easy in regeneration areas to deter inward investment by what are seen
to be over-restrictive development control policies. One way of addressing
this problem is to avoid using accessibility measurements (and hence
parking standards) that anticipate medium and long term investment in
public transport. However, account must be taken of committed schemes
that will deliver benefits within a few years and also of improvements
flowing from developer contributions, otherwise car parking over-provision
would undermine the viability of these transport investments and quickly
establish unsustainable travel habits. Phased reductions in parking
provision are one way of ensuring longer term sustainability without
deterring short term investment.

3.20 A matrix of the form illustrated overleaf seeks to address these issues. It
assumes a relationship between PTALs, mode split and parking provision
to interpolate between zero and demand-based parking provision (in the
absence of data that would better define the relationship). A curved
relationship could be convex in an upward or downward direction or a
straight line could be used (see illustration below). The first of these would
limit the onset of major reductions in parking provision until high PTAL
values were reached. The last would introduce relatively bigger reductions
at lower PTALs. A straight line would be a simple compromise.

% of unfettered demand
provided
100
90
80
70
60
50
40
30
20
10
0
1 2 3 4 5 6
PTAL

26
Retail land uses:
Percentage of relatively unfettered car parking demand
that could be provided

retail land use PTAL

6 5 4 3 2 1
best worst
smaller foodstore 0 40 60 75 85 100
food supermarket 0 40 60 75 85 100
food superstore 0 40 60 75 85 100
non-food warehouse 0 40 60 75 85 100
garden centre 0 40 60 75 85 100
local centre/shopping mall 0 40 60 75 85 100
Notes:
SHADED CELLS indicate where development would not normally be
permitted; parking standards derived from this approach would help test the
adequacy of existing or proposed public parking supply, for exceptional
cases and to help judge disabled parking provision (see below). In town and
local centres in Outer London, development may be permitted with PTALs of
3 (lighter shading).
All of the central London area is assumed to be PTAL 6. Outer London
locations scoring PTAL 6 may require some parking, but this should be
determined by a Transport Assessment.
In designated REGENERATION AREAS, car parking provision could initially
be based on the next LESS RESTRICTIVE standard in the matrix, followed
by progressive reductions for subsequent phases as public transport
accessibility improves.
Where a site has substantial local WALK AND CYCLE CATCHMENTS that
are very accessible, car parking provision should be based on the next
MORE RESTRICTIVE standard in the matrix.
OTHER FORMS OF RETAIL DEVELOPMENT should normally have no
dedicated on-site parking provision and should rely on the public parking
supply, which should be adequate in PPG 6 terms. The standards above
may assist a review of the adequacy of the public parking supply.
ALL developments should provide for secure cycle parking.
ALL developments should include provision for car parking/car-based access
for disabled people in accordance with TA 5/95.

27
3.21 We have chosen a “curve” that is convex in an upward direction as the
basis for determining the amount of parking to be provided. We consider
this provides a suitable starting point for the TA process and avoids
unrealistic assumptions about levels of non-car use in locations with
relatively poor public transport accessibility. This is intended to help
support viable development in a range of locations rather than just in the
most accessible.

Proposed retail car parking standards

3.22 Where the approach indicates that substantial car parking is necessary for
development viability and economic revitalisation, the first step is to
consider the adequacy of public parking and its role in the Borough’s
Parking Plan. Where it is judged that public car parking provision is
inadequate (and the Parking Plan is policy-compliant in its treatment of car-
based commuting) then additional on-site car parking may be appropriate
as part of the development. Any such provision must also be available to
the general public to ensure that the town centre benefits as a whole, in
accordance with PPGs 6 and 13.

3.23 The proposed approach to maximum retail car parking standards is set out
in the matrix overleaf, based on the approach explained above.

28
Maximum car parking standards for retail uses

retail land use PTAL

6 5 4 3 2 1
best worst
1 space per x m2gfa
smaller foodstore 75 50 40 35 30
(up to 500m2gfa)
food supermarket 45 30 24 21 18
(up to 2500m2rfa / c4000m2gfa)
food superstore 38 25 20 18 15
(over 2500m2rfa)
non-food warehouse 88 58 47 41 35
garden centre 63 42 33 29 25
local centre/shopping mall 75 50 40 35 30
Notes:
BLACK CELLS indicate that no non-operational parking should be provided.
SHADED CELLS indicate locations that would normally be regarded as inappropriate for the
development type; however, standards are indicated:
 to help test adequacy of existing or proposed public parking supply
 for exceptional cases
 to help judge disabled parking provision (see below).
However, in town and local centres in Outer London, development may be appropriate with
PTALs of 3 (lighter shading).
OTHER RETAIL FORMATS (eg high street shops, department stores) would be expected to rely
on the public parking supply and have no on-site parking provision.
In designated REGENERATION AREAS, car parking provision could initially be based on the
next LESS RESTRICTIVE standard, followed by progressive reductions for subsequent phases
as public transport accessibility improves.
Where a site has substantial WALK AND CYCLE CATCHMENTS with good accessibility, car
parking provision should be based on the next MORE RESTRICTIVE standard.
The food retail size thresholds are discretionary and should not be used to avoid appropriate
parking reductions.
OTHER FORMS OF RETAIL DEVELOPMENT should normally have no dedicated on-site
parking provision and should rely on the public parking supply, which should be adequate in
PPG 6 terms. The standards above may assist a review of the adequacy of the public parking
supply.
ALL developments should provide for secure CYCLE PARKING.
ALL developments should include provision for car parking/car-based access for DISABLED
PEOPLE in accordance with TA 5/95. This is based on unfettered parking demand
The above standards are MAXIMUM STANDARDS; more restrictive standards are acceptable in
appropriate circumstances (eg in a very robust local economy).

29
3.24 TfL has recently collated parking standards currently adopted/proposed by
London Boroughs. These figures are based on information supplied by the
Boroughs in February/March 2001 and updated to reflect subsequent UDP
reviews.

3.25 The exercise indicates wide variation in retail standards across London,
ranging from limited or zero parking in critical Central London Boroughs
(e.g. City, Westminster, Camden) to provision for unfettered demand in
Outer London Boroughs (e.g. Barking and Dagenham, Bexley, Havering,
Sutton) and some instances of over-provision relative to national data on
the travel characteristics of new development. While Havering’s standards
(adopted in 1993) appear to pre-date the first issue of PPG 13 in 1994,
Barking and Dagenham appears to be the only Borough with minimum, not
maximum standards (note: no information is given in the table on this latter
point for Hammersmith and Fulham and Croydon).

3.26 It is interesting that a significant number of Boroughs already seek to align

their standards with spatial variation in accessibility. This approach seems
to be mainly applied to retail (and some employment) standards, although
two Boroughs (Enfield and Merton) appear to be applying it to leisure uses
also. Some Boroughs make a distinction between “centres” and
“elsewhere” while the majority using a spatial approach refer to “low”,
“medium” and “high” accessibility levels (the table does not specify whether
or not this is PTALs-based). PTALs, however, is clearly identified as the
basis for Barnet’s standards, adopted in 2000, resulting in a fourth
accessibility level, described as “very high”.

3.27 Current practice is therefore substantially aligned with the overall approach
developed independently by this study.

The proposed approach to leisure developments

3.28 We consider that leisure developments should be treated differently to retail
developments. There is a wide variety of leisure formats and leisure activity
generally does not involve bulk purchasing or carrying heavy equipment. It
commonly takes place during evenings when people are less pressed for
time and when the public car parking supply is under-used. We can
assume that people are prepared to walk further (from car parks, public
transport termini etc) in these circumstances. PPG 6 indicates that the
preferred location for many (but not all) leisure developments is in town
centres where there are linked trip opportunities and a choice of transport
modes. Public transport is also more likely to be good or better (PTALs 4-
6) in town centres. It is appreciated that some leisure formats are not
suitable for town centre locations (eg golf courses).

30
3.29 We recognise that public transport service provision usually reduces later in
the evening and that car use is seen to offer better personal security for
lone females especially. It is also recognised that car park security can be
poor at night and where this is the case, section 106 contributions should
be sought to improve the situation.

3.30 Taking these points into account, we therefore propose that the starting
point for determining car parking provision at leisure developments is that,
where appropriate, these should be preferably in town centre locations with
an adequate public car park supply and that no dedicated on-site parking
should be provided with the development.

3.31 We recognise that:

 some leisure formats cannot compete with retail uses in town

centres because of the high rental values sought

 given competition for town centre sites, some developments will be

more appropriate for edge-of-town locations, although the
sequential test will still apply; parking provision should reflect
PTALs in an interpolation process (between zero spaces and
provision for unfettered car use) in a similar way to retail, but
assessed by the Transport Assessment

 some idea of parking standards that allow for unfettered demand is

useful for testing the adequacy of the public parking supply

 some leisure uses that are incompatible with town centre locations,
will be located on out-of-town sites and will generally have to be
accepted as car-based (eg golf courses)

 provision may have to be made for coach parking where substantial

numbers of participants and spectators are expected (eg sports
stadia)

 the variety and scale of leisure developments means that many

larger developments must be assessed on an individual basis rather
than by reference to standards

 for some sports facilities account needs to be taken of the

simultaneous presence on-site at any one time of sports
participants (for example) who are preparing to participate, those
who are participating and those who have finished but have not left
the facility; this increases occupancy beyond what may be inferred
from the number of courts, lanes etc provided.

31
Proposed leisure car parking standards
3.32 As established above, on-site parking should not normally be permitted at
leisure developments in town centres where the public parking supply is
sufficient. In other locations some parking will be required and
consideration should be given to using PTAL values to take account of
journeys by other modes to reduce the amount of parking required. The
matrix overleaf shows parking standards that reflect relatively unfettered car
use, but the Transport Assessment should be used to determine the
expected level of parking required taking account of accessibility by non-car
modes. The parking standards also provide a benchmark for assessing the
adequacy of publicly provided car parking in the centre.

3.33 Where a large scale development is of national and/or regional importance,

a direct rail connection will generally be an important consideration.
Residual parking provision should be assessed in the light of such
considerations.

3.34 It is recommended that the standards indicated should not be exceeded.

Bars and other such facilities should be treated as ancillary to the main use
(eg bars at tennis clubs, swimming pools etc) and reductions in the
individual standards should be considered where there is mixed
development (eg cinema and ten pin bowling). Mixed use developments are
discussed further in Section 4.

3.35 The proposed approach to maximum leisure car parking standards is set
out in the matrix overleaf.

32
Maximum car parking standards for leisure uses

leisure land uses standards

cinemas and theatres 1 space per 5 seats
bingo 1 space per 5 seats
ten pin bowling 4 spaces per lane
indoor bowls 4 spaces per lane
squash courts 3 spaces per court
fitness and sports clubs 1 space per 22m2gfa
tennis and badminton 4 spaces per court
outdoor sports grounds* 1 space per 4 players plus
1 space per 5 spectators
stadia individual assessment
golf courses (18 hole) 100 spaces
golf driving range 1.5 spaces per tee
swimming pool 1 space per 22m2gfa
conference facility 1 space per 5 seats
clubs and dance halls 1 space per 2.5m2 bar area
riding centre 1 space per loose box/horse
caravan and camping sites 1 space per pitch
Notes:
CLEAR CELLS indicate that the development would normally be out-of-
town in which case a parking standard reflecting unfettered car use would
be the starting point for the Transport Assessment, except for stadia,
which should be located in places with good or excellent public transport
accessibility (PTALs 4-6) and parking provision adjusted accordingly.
SHADED CELLS indicate that the development should preferably be in a
town centre in which case dedicated on-site parking would not normally
be permitted and that the public parking supply should be used;
unfettered parking demand standards are provided:
 to test adequacy of existing or proposed public parking supply
 to assist determination of provision at edge-of-centre sites
 for exceptional cases
 to help judge disabled parking provision (see below).
*Commercial proposals attended by large numbers of paying spectators
should be assessed individually.
ALL developments should provide for secure CYCLE PARKING.
Specific provision for COACH PARKING may be appropriate.
ALL developments should include provision for car parking/car-based
access for DISABLED PEOPLE in accordance with TA 5/95. This is
based on unfettered parking demand.
The above standards are MAXIMUM STANDARDS; more restrictive
standards are acceptable in appropriate circumstances (eg in a very
robust local economy with excellent public transport).

33
3.36 The following paragraphs describe the technical context for this approach to
parking standards.

Transport Assessments, parking standards and Travel Plans

3.37 PPG 13 (Revised) introduced the concept of Transport Assessments (TAs).
TAs replace traffic-orientated Transport Impact Assessments (TIAs). The
Government is due to issue guidance on TAs. TAs should concentrate
initially on the location of new development and existing and proposed
transport infrastructure to see how this can be used to maximise the use of
non-car modes and to reduce the need to travel. Only when these
processes have been undertaken should attention turn to traffic-related
issues.

3.38 Government guidance accepts that the private car will remain the most
common mode outside the centres of major towns and conurbations and
highways provision should be designed accordingly to ensure safe traffic
conditions are maintained, above all else. However, this new emphasis on
non-car modes in TAs should help ensure that off-site highways work and
on-site layouts incorporate high quality accessibility for pedestrians, cyclists
and public transport users as an integral part of the design, rather than an
optional extra.

3.39 One of the outputs of a TA will be an estimate of car parking demand.

What then is the role of parking standards? Parking standards give an
early indication to the TA process of the levels to which car use is expected
to be reduced. This can be compared with the output of the TA. Where
necessary, an iterative process can be used to reconcile the parking
standard used as an input to the TA and the TAs assessment of parking
demand. Significant deviation from the standard would need to be justified
and would not normally be permitted.

3.40 Where car parking provision is proposed below that considered appropriate
in the light of this guidance, developers will have to justify their confidence
in the take-up of non-car modes in order to ensure that the development will
be viable without damaging parking overspill in adjacent streets.

3.41 Travel Plans are required to accompany TAs as directed by national

guidance. Travel Plans should propose soft (policy and behavioural) and
hard (physical infrastructure) measures to ensure delivery of TA forecasts
and sustainability ambitions. Both should be compatible with proposed
parking arrangements.

34
Operational parking
3.42 The proposed approach to retail and leisure standards accepts that a
minimal amount of operational parking may be required on-site.
Operational parking is that which is required to enable the development to
function. It can include arrangements for maintenance and servicing but it
specifically excludes customer and employee car parking except for
“essential car users” (ie car use without which a development could not
operate). Operational car parking provision is included in the standards
developed for this study as such use is included in the survey data used to
establish parking standards relating to unfettered demand.

3.43 The onus would be on the developer to present the case for operational car
parking and service vehicle requirements in excess of recommended
parking provision or where non-operational car parking would not be
permitted. It is always important to remember that planning permissions
are attached to the land in question, not the prospective occupier (if known).
Hence any exceptional provision of operational space may be surplus to
future requirements if the prospective occupier fails to materialise or the site
is vacated. Genuine need for operational parking (eg a large car-based
sales force) should be minimised through the use of a Travel Plan to reduce
peak parking demand, for instance, by re-organising work patterns and/or
facilitating home-working.

Parking for disabled people

3.44 Disabled people are known to often prefer the special accessibility, safety
and convenience that only a private car can provide. Accordingly, all new
retail and leisure developments should make appropriate allowance for
disabled access and parking in accordance with Government advice leaflet
TA 5/95 and related guidance. TA 5/95 relates parking provision for
disabled people to unfettered parking demand in order to avoid penalising
the disabled.

Cycle parking
3.45 Appropriate provision should be made for secure cycle parking and for
other facilities that encourage cycling (eg showers). We understand that
cycle parking standards will be the subject of future work by TfL, in
consultation with the Boroughs.

Coach parking
3.46 A number of sports and other leisure activities generate a demand for
coach parking. Establishing the demand for such parking is one role of a
TA. A TA should accompany all significant development proposals, in line
with DTLR guidance issued in 2001.

35
36
4: Mixed use developments
Mixed use developments involve a variety of retail, leisure and other elements on
one site. Car parking may or may not be physically related to each element. The
time profiles of car parking demand vary according to use. If the peak parking
demands for each element are added together, the total will generally exceed the
expected peak parking demand for the development as a whole. Such over-
provision should be avoided through appropriate analysis.

Technical approach
4.1 It will not be possible for the GLA to indicate specific parking standards for
mixed use developments because they are all different and each element
could have very different parking characteristics. As explained below, the
general principle is that total parking provision should be less than that
which each element could warrant individually.

4.2 Research for the TRICS consortium (Transport Characteristics of Non-Food

Retail Parks, TRICS Report 97/1, 1998) shows the extent of this variation.
The conclusions from the research are as follows:

 the mix of stores is highly relevant

 some stores act as anchors for the rest, resulting in linked trips on-
site

 there may be on-site competition on the same park

 operators can change over time

 adjacent food retailing adds to the propensity for linked trips.

 transport assessments should take account of these features.

4.3 A similar pattern will apply to mixed leisure developments.

4.4 Large mixed use developments have tended to be on out-of-centre sites

because large enough sites rarely exist in or next to town centres. Public
transport accessibility will not normally be as good as in a town centre
unless the scale of development is such that a new rail station is proposed
as part of the development. Even then, it is normally very difficult to
replicate the range of transport services normally available in a town centre.

37
4.5 Planning inspectors have been very suspicious at appeal (as documented
in the Transport Appeals Journal) about ambitious claims for public
transport usage in these circumstances. They point out that catchments
can be large and complicated and that bus services will not readily be re-
orientated to provide the necessary network, especially in the evenings or
at weekends. They note that decisions to build new stations are ultimately
not in the hands of the developer and that third party land may easily be
involved, creating similar problems of uncertainty and unpredictability.
However, if the development has a regional or even national catchment
then an on-site rail station assumes much greater importance as rail
becomes much more competitive compared with car use.

4.6 Sequential testing as required by PPG 6 may undermine the large mixed
use development concept by showing that individual town centre sites could
provide a similar offer in aggregate. Developers’ claims for the indivisibility
of large concept stores/developments are no longer readily accepted by the
Government or the Planning Inspectorate.

4.7 The key to identifying transport impacts (and hence parking provision) lies
in an appropriate TA supported by retail and leisure impact studies. This is
the only way of understanding the likely catchment and competition impacts
of large mixed use developments, both of which affect transport impacts.

4.8 The TRICS research shows that trip rates for retail parks are significantly
lower than for most of the individual elements in isolation. Parking provision
should be reduced correspondingly. Linked trip-making can reduce parking
demand by up to 50%, and 25% appears readily attainable. It will remain
up to developers to demonstrate such effects in their TAs.

38
5: Parking standards for other uses,
excluding employment generating &
residential
This section sets out an approach to car parking standards for other uses as
identified above. This proposed approach for London draws on the same data
sources as the initial commission (eg TRICS/TRAVL) and takes account of the
approach proposed for retail and leisure uses. We have also taken account of
standards recently adopted/proposed by local authorities in the South East of
England. The latter tend to be historical standards but modified to eliminate over-
provision.

London guidance on parking standards for employment generating uses was

initially set out in RPG 3, but has since been modified by RPG 9. PPG 3 and RPG
9 set out national and regional guidance on parking provision for residential uses.

Each Use Class is considered in turn below.

A2 Financial and professional services

5.1 This Use Class includes banks, building societies, estate agencies,
employment agencies, betting offices and professional and financial
services. In considering parking standards, a distinction needs to be made
between the headquarters-style buildings of financial institutions and High
Street banks, building societies etc. The former should be treated as B1
offices and the established approach for employment generating uses
should be applied.

5.2 The presumption is that banks, building societies etc will be centrally
located and ancillary to the retailing function of the centre. Customers are
likely to visit the bank as part of a linked trip on foot and the public parking
supply should be used. No site-specific parking provision is appropriate.

A3 Food and drink

5.3 This Use Class includes restaurants, pubs, bars, cafes and hot food
takeaway shops. The proposed starting point for this Use Class is that no
parking provision should be made in central locations, where the public
parking supply should be used, or on mixed-use sites (i.e. retail/leisure
parks), where food and drink should be treated as ancillary to other uses.

39
 The presumption is that most food and drink establishments will be
developed in these two locations. However, this will not always be
practicable for the following types of food and drink developments:

 roadside restaurants and fast-food drive-through restaurants (not

permitted centrally and customers tend to be car-borne)

 pub restaurants (if permitted out-of-centre/town).

5.4 Maximum car parking standards for roadside restaurants, fast-food drive-
through restaurants and pub restaurants are proposed below.

Maximum car parking standards for selected food

and drink uses

food & drink uses standards

roadside restaurants 1 space per 10 m² gfa
fast-food drive-through 1 space per 10 m² gfa
restaurants*
pub restaurants 1 space per 10 m² gfa
(up to and including 1,000 m² gfa)
1 space per 20 m² gfa
(over 1,000 m² gfa)
Notes:
These developments would normally be out-of-centre/town in which case
a parking standard reflecting unfettered car use (as tabulated) would be
the starting point for the TRANSPORT ASSESSMENT.
ALL developments should provide for secure CYCLE PARKING.
ALL developments should include provision for car parking/car-based
access for DISABLED PEOPLE in accordance with TA 5/95. This is
based on unfettered parking demand.
The above standards are MAXIMUM STANDARDS; more restrictive
standards are acceptable in appropriate circumstances (e.g. with
excellent public transport or where shared parking can be justified for say
a drive-through restaurant on a retail/leisure park or a pub restaurant
adjacent to an hotel).
Maximum standards reflect UNFETTERED CAR USE as represented in
TRICS/TRAVL data and previous reviews of standards adopted/proposed
by local authorities in the South East of England.
* Fast-food drive-through restaurants contain a seating area as well as a
drive-through facility. Where no seating is provided, little more than
operational parking will be required.

40
B8 Storage or distribution
5.5 This Use Class includes wholesale warehousing, distribution centres and
repositories. Therefore, it cannot sensibly be included within RPG 3’s
“employment generating” category and hence some guidance is provided
below:

 a B8 standard of 1 space per 75 – 100 m² gfa is considered to be Formatted: Bullets and Numbering

representative of unfettered car parking demand but any associated

office accommodation should be treated as offices in determining
overall parking provision

 requests for lorry parking should be checked against the following

benchmark range: 1 lorry space per 200 m² gfa (minimum 1 lorry
space) to 1 lorry space minimum plus 1 lorry space per 500 m² gfa.

5.6 The presumption is that most storage or distribution developments are likely
to be located out-of-centre/town, with the focus of attention on operational
requirements rather than staff/visitor parking. Hence unfettered demand
would appear to be an appropriate starting point for the TA process and
identification of appropriate parking provision.

C1 Hotels
5.7 This Use Class is concerned with hotels, boarding houses and guest
houses. The proposed approach is that car parking should largely be
assessed on an individual basis as part of the Transport Assessment
process, with location, scale and format being key considerations. It is
envisaged that:

 small hotels, particularly those in central London will have no

parking provision

 large hotels will have varying degrees of parking provision, taking

into account relevant factors such as public transport accessibility,
target markets, the mix of domestic and international clients and the
implications of conference and sports facilities

 peripheral hotels on key arterial roads (e.g. Travel Inns) rely on car-
borne trade and are likely to require unfettered parking provision.

Individual assessment is proposed as the parking requirements of hotels

can vary substantially, particularly in the London context.

41
5.8 A benchmark maximum standard (based on unfettered demand) is
considered to be of the order of 1 space per bedroom.

5.9 Coach parking requirements should also be considered as part of the

Transport Assessment process.

C2 Residential institutions
5.10 This Use Class includes residential schools/colleges and hospitals and
convalescent/nursing homes. The proposed approach is that car parking for
residential schools/colleges and hospitals should be assessed on an
individual basis as part of the Transport Assessment process.

5.11 Individual assessment is proposed as new residential schools/colleges and

hospitals are not common occurrences. In particular, the nature of hospitals
can vary substantially. Travel Plans should play an important role in any
Transport Assessment for educational facilities and hospitals, together with
other important considerations such as patient and staff catchments,
location and non-car accessibility. Where a proposal involves relocation or
reorganisation (as may well be the case in respect of hospitals), data on the
existing catchment and travel patterns can provide a valuable input into the
assessment process. The same can apply to educational establishments.
Account should be taken of the number of staff permanently
accommodated on-site. Many hospitals have instituted quite stringent
restrictions on staff car parking as the use of available land is maximised for
patient care. It is expected that many patients and most visitors will be car-
dependent, as the very young and elderly form a large proportion of the
patients’ profile.

5.12 Proposals for new nursing homes occur more commonly and tend not to be
centrally located. A benchmark maximum standard (based on unfettered
demand to cater for resident staff and visitors) is considered to be of the
order of 1 space per 2-4 beds.

D1 Non-residential institutions
5.13 This Use Class includes a wide variety of non-residential institutions:

 places of worship and religious halls

 clinics, health centres, crèches, day nurseries and consulting rooms

 museums, public halls, libraries, art galleries and exhibition halls

 non-residential education and training centres.

42
5.14 The proposed approach is that car parking for non-residential institutions
should largely be assessed on an individual basis as part of the Transport
Assessment process. One possible exception is surgeries/consulting
rooms (see below).

5.15 Individual assessment is proposed as many of the development types

within this Use Class do not commonly arise as new development and there
is limited data on which to base benchmark standards. The nature of
proposals can also vary substantially for a given development type.
Important considerations will include catchments/target markets, location,
non-car accessibility and public parking supply (particularly relevant for
health and cultural facilities). Travel Plans will also have an important role
to play, particularly in respect of educational facilities. It is envisaged that:

 places of worship/halls will require at least some parking to cater for

large gatherings drawn from a wide catchment e.g. in the case of
weddings and funerals

 clinics and health centres are likely to be centrally located, but may
require some parking depending upon the size of the catchment
and the adequacy/convenience of the public parking supply; the
elderly and infirm prefer to use a car where possible

 crèches/day nurseries may require a dropping-off/collection area

rather than “long-stay” parking provision

 surgeries/consulting rooms in central locations are unlikely to have

dedicated parking but some provision will be required by those in
more peripheral locations (see paragraph 5.16 below)

 museums, public halls, libraries, art galleries and exhibition halls are
likely to be centrally located and visitors can make use of the public
parking supply

 non-residential education and training centres are likely to require

some parking for staff and pupils over the age of 17 but the focus of
attention should be on child safety (see paragraph 5.17 below).

5.16 In respect of surgeries/consulting rooms, a benchmark maximum standard

(based on unfettered demand) is considered to be of the order of 4 spaces
per consulting room.

43
5.17 In respect of parking provision for non-residential education:

 Travel Plans, Safe Routes to School programmes etc should play

an important role

 segregation of vehicle and pedestrian movements on site should be

a key design criteria

 safe and convenient dropping-off/collection areas should be

provided for parents’ cars and coaches/school buses

 any overspill parking for uses outside the school day should be
accommodated through the use of dual purpose surfaces (e.g. all-
weather play areas, courts etc) as appropriate.

We note that the only maximum standard included in PPG 13 for education
relates to higher and further education above 2,500 m² gfa: 1 space per 2
staff plus 1 space per 15 students.

Parking for disabled people

5.18 As discussed in Section 3, all new developments should make appropriate
allowance for disabled access and parking in accordance with Government
advice leaflet TA 5/95 and related guidance. TA 5/95 relates parking
provision for disabled people to unfettered parking demand in order to avoid
penalising the disabled.

Cycle parking
5.19 Appropriate provision should also be made for secure cycle parking and for
other facilities that encourage cycling (e.g. showers). Indicative standards
are provided in the London Cycle Network Design Manual 1998. We
understand that cycle parking standards will be the subject of future work
by TfL, in consultation with the Boroughs.

44
6: Conclusions and recommendations
This concluding section summarises conclusions reached and the recommended
way forward. In addition to this report, Harrison Webb assisted in the initial drafting
of a policy statement on parking standards in the form of an Annex for inclusion in
the Mayor’s Spatial Development Strategy.

Conclusions
6.1 In the course of this study, we reached the following conclusions:

 the standards proposed must be compatible with national policy

guidance but also reflect London’s special needs and
characteristics

 locational policies for new development are critical and will not be
influenced by any significant future change in London’s road
network as this is not practical; locational policy should prevent
perverse incentives to develop in unsuitable locations

 parking standards are subservient to locational policies that seek to

direct major new development to areas where public transport
accessibility levels are good or excellent

 standards should be used in a way that reflects the spatial variation

in accessibility by non-car modes, especially public transport

 public transport accessibility levels (PTALs) provide the basis for

both locational policy and car parking standards; major new
development should generally only be permitted where PTAL
scores 4 to 6 are achieved, smaller scale development is more
appropriate for areas with lower PTALs

 parking standards should be broadly derived from the maximum

standards set out in PPG 13 that apply to retail and leisure uses

 it is not reasonable to use RPG 3/RPG 9 employment standards as

a structure for setting retail and leisure standards in London

 proposed changes to the planning system are unlikely to affect the

way standards will be presented or applied

 pan-London consistency can be assisted by relating parking

provision to accessibility by non-car modes, primarily (but not
exclusively) in relation to PTALs

45
 walk and cycle accessibility and economic regeneration also need
to be reflected in the process

 retail standards should be based on progressive reductions in the

level of parking provision that would reflect relatively unfettered car
use, whilst noting that locations that are car-dependent are
generally unsuitable in view of the sequential test

 a matrix format for retail parking standards allows parking provision

to be related to PTALs, walking and cycle accessibility, regeneration
and over-riding locational policies

 the matrix should reflect the fact that social change has brought
relative car dependency for some retail formats and that this is
unlikely to disappear in the foreseeable future; such development
should be located where accessibility by non-car modes is good to
minimise car dependency and necessary car parking should rely on
publicly available spaces as far as possible

 many other retail formats do not require dedicated on-site car

parking and should rely on the public parking supply

 leisure developments should normally rely on the public parking

supply except where the format is obviously not suitable for a town
centre location or where after applying the sequential test, an edge
of town centre location with lower public transport accessibility is
selected

 the findings of this study will be translated into guidance in the SDS
which the Boroughs can interpret to produce parking standards for
inclusion in their UDPs

 parking standards should provide an input to Transport

Assessments and Travel Plans and an iterative process used to
ensure compatibility with residual traffic impacts; the standards
represent guidance but are intended generally not to be exceeded

 explicit account should be taken of operational parking

requirements, cycle parking, coach parking and parking for the
disabled

46
  subject to the sequential testing process, parking at mixed use
developments should be assessed by reference to location, the mix
of uses, future changes in operator and linked trips on-site; mixed
use will reduce the demand for parking overall.

Recommendations
6.2 We make the following recommendations:

 that the report is used as the basis for an Annex on parking

standards in the Mayor’s London Plan

 that the matrices in the report and supporting notes are adopted as
a framework for determining parking standards for new
development

 that Transport Assessments are used to ensure compatibility

between parking provision and residual traffic impacts (having taken
the opportunity to maximise accessibility by non-car modes),
acknowledging that an iterative process may be required to
reconcile parking standards, the findings of TAs and the provisions
in Travel Plans

 the reliance on PTALs means that we recommend TfL owns,

maintains and updates such information annually, and considers
how best to provide guidance about forecasts based on future
transport investment

 that this report and its conclusions and recommendations are

subject to further consultation with London authorities and business
interests prior to and during consultation on the draft London Plan.

GLA parking standards/final report July 2002

dah/ljw/final report July 2002

47
48
 Appendix A
Consultation findings

49
50
Consultation findings
A small representative sample of London Boroughs were consulted on the main
findings of this study. Responses were received from 5 London Boroughs and are
discussed below.

Main point
No consultee disagreed with the basic approach, although there was some concern
about the use of PTALs to represent public transport accessibility. Comments are
addressed below with an indication of how the main text has been adapted where
thought necessary.

Comments
1 Why not make greater/specific use of TRAVL rather than TRICS?

TRICS is by far the bigger database and gives a national perspective of

relatively unfettered car use. This will help avoid external boundary effects
if used as the starting point for restraint-based policies in London. TRAVL
and TRICS show broadly compatible trip rates at the higher levels of car
use

2 The reference in para 2.19 to 80% car use for commuting outside London
and possibly in Outer London needs justifying as it seems very high.

Transport Statistics GB 2001 shows in Table 1.7 that main mode used for
journeys to work was as follows:
% by car
England 70
North West excl. mets 78
North East excl. mets 76
Yorks Humber excl mets 71
East Midlands 74
West Midlands excl mets 78
East of England 76
South East 76
South West 75

Central London 13
rest of Inner London 41
Outer London 68

51
 Suggested rewording:
…unfettered car use is likely to be represented by between 70 and 80% of
commuting trips being by car.

3 Para 2.24 makes a statement about the importance of adequate town

centre short stay parking supplies when considering retail and leisure
parking standards. Guidance on how to assess this should be provided.

Suggest we note that PPGs 6 and 13, LTP guidance and the Mayor’s
Transport Strategy all refer to the universal need for town parking plans.
This is the appropriate source of judgement about adequacy.

4 The use of PTALs as a pan-London parameter is questioned. The transport

utility of a given value may vary between, say, Inner and Outer London.

The PTAL approach may not be perfect but it brings consistency and can
be further developed via the PTAL working group. It is used as a starting
point for setting retail standards and, hence, for Transport Assessments
(TAs). If there is a sound basis for suggesting that PTAL 4 in say Hounslow
has a different utility to the same level in Westminster then this can be dealt
with in the TA. The Mayor will make a judgement about the weight to be
attached to the argument if he is involved in the application process.
Developing different standards for different areas of London with the same
PTAL would introduce more boundary effects. The iterative process in TAs
should help resolve this problem.

Suggest that text about applying PTAL is reviewed but the approach
maintained. Modify the standards such that PTAL 3 would be acceptable
for retail uses in town and local centres in Outer London.

5 Economic vibrancy should be a quantified parameter. Regeneration areas

should not be allowed to avoid restraint as this would tend to breed bad
travel habits.

As we are only suggesting a marginal relaxation for regeneration areas,

there is no point is quantifying local economic performance. It is not a
continuous variable. This relaxation would be accompanied by Travel
Plans etc to influence behaviour.

6 The need for complementary parking polices is accepted ref para 2.3. But
developers should not be given impression that they pay 100% of costs.
Overspill is not automatic when on-site parking is less than unfettered
demand as mode split should alter according to relative accessibility.

Suggest in text that complementary controls are not necessarily required in

every case and may not be solely the responsibility of the developer.

52
7 Report should refer to Planning Green Paper and daughter document on
contributions. Developer contributions should relate to traffic impacts and
not be so great as to deter investment.

53
 Green Paper is referred to but the daughter document is not.

Suggest reference is made to daughter document, noting that our

suggested approach anticipated government proposals and is broadly
compatible (but perhaps preferable, see below). We should note that the
proposed approach should not be a greater burden on development but
predictable and transparent. The Government’s preferred approach may
not achieve its desired objectives and does not apply to smaller
developments, the overall impact of which will exceed that of the small
number of larger developments. Relating tariffs to traffic impacts is
unnecessarily complicated as impacts could be challenged. Relating tariffs
to parking provision as we suggest effectively does this simply and easily.
Contributions should not be so great as to encourage Councils to operate
non-compliantly to maximise income.

8 Approach should be able to quantify pedestrian and cycling accessibility.

Disagree, on basis of same argument above about economic parameter.

Suggest text supports judgement about this based on accessibility criteria in
PPG 13.

9 More guidance needed on cycle parking standards.

The study brief did not require us to provide such standards. An appendix
of draft standards was included in the consultation draft for completeness
but had not been researched in a specific London context. Suggest cycle
standards are omitted from text. It is understood that they will be subject of
future TfL work.

10 Developers are going to suggest that reduced parking provision (eg in town
centres) makes development non-viable. Public parking can’t always cope.

Agree that parking provision is important but some developers now have
low (or zero) parking formats for “traditional” car-orientated shopping in
town centre or highly accessible locations (eg Tesco Metro format; recent
Tesco appeal in Lambeth for 2512m2 retail floorspace was allowed by the
SoS provided no more than 98 spaces were provided (at 1 space to 26m2
ie approaching 50% of unfettered demand).

54
 It is not appropriate to attract higher car use in town centres. It may be OK
in edge-of-centre or local centre locations that still allow linked trips and
support the local retail economy. Developers may provide parking above
the prescribed standard on the basis that it helps make town centre parking
adequate as per PPGs 6 and 13. Developers would need to prove need for
a car-orientated retail format, in PPG 6 terms.

Suggest no change of message but strengthen text.

11 Developers should be able to provide less parking than standards suggest

(ref para 3.30). To suggest otherwise would be contrary to government
guidance.

Parking provision must be realistic in the circumstances prevailing. The TA

process should highlight where unrealistically low provision could lead to
unwanted overspill impacts. Parking provision has to be appropriate for the
purpose. The PPG 13 phrase about developers not being forced to provide
more than they want is unfortunate in this context although compatible with
the switch from minimum standards.

Suggest no change of message.

12 Personal security is part of pedestrian accessibility judgement.

Agree.

Suggest text makes this clear.

13 Central London offers completely different lifestyle options and PPG 13

standards are completely inappropriate; the conclusions should make this
clear.

Agree. Our approach is compatible with zero parking provision in such

circumstances although disabled and cycle provision is still needed. PTALs
in this instance is a proxy for the range of choice available on foot or via
convenient public transport.

We gratefully acknowledge receipt of Westminster’s latest standards in this

respect.

Suggest Section 2 notes the point about PPG 13 standards in Central

London.

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14 All LBs should be consulted on this subject.

This is a matter for the GLA but the SDS will have its own consultation
process to which all LBs could contribute.

15 Outer London town centres may not comply with the ”preferred” PTALs
range of 4 to 6 and development could be inhibited.

Suggest we consider that lower “limit” should be 3 in Outer London) rather

than 4 or imply some flexibility in such circumstances by noting that the TA
process should take on board all aspects of a development.

16 Text suggests Bexley’s current standards over-provide parking at retail

development and this is not the case.

Agree wording is ambiguous.

Suggest wording changed to …provision for unfettered demand in Outer

London Boroughs (eg Barking and Dagenham, Bexley, Havering, Sutton)
and some instances of over-provision relative to national data on the travel
characteristics of new development.

56
57
 Appendix B
Findings of previous work
on developer contributions

58
59
Developer contributions
1 Previous commissions have involved reviews of policy on developer
contributions. These commissions pre-dated the Government’s current
consultation document. We advocated a two strand approach.

2 One strand of developer contributions would continue to be through

agreements made under section 106 of the Town and Country Planning Act
1990. This would be the first strand. Such contributions would relate to
specific measures that support necessary improvements in physical and
social infrastructure and so on as a direct consequence of the development.
Agreement-based contributions would not necessarily reflect a need,
identified in an LTP/LIP, specifically or generally, for off-site measures in
the general area or corridor within which the development lies.

3 A procedure for funding these measures through commuted sums

represents the second strand. A fixed tariff per parking space provided on
a development site could sit alongside contributions under section 106
agreements. This approach would:

 reward developers who wish to locate development in preferred

(more accessible) locations, as on-site parking provision could be
reduced below the levels required at less accessible sites without
threatening viability

 penalise developers who wish to locate in sub-optimal locations

(less accessible) if a proposal survives appropriate sequential tests

 comply with government policy by making town centre development

cheaper than out-of-centre development in these terms

 provide greater certainty for developers (and TfL) and could be

linked to LIPs

 be transparent, predictable and easy to build into standard

agreements.

60
4 This two-strand approach is broadly compatible with the preferred option in
the Government’s daughter document (to the Planning Green Paper) on
planning obligations. This can be summarised as follows.

5 The Government is seeking reactions to a system based on a standard tariff

set locally through the local plan process that could be varied by a
negotiated element where this is necessary to address the particular
circumstances of a development. The most obvious example of the latter is
the need to deal with site conditions or access but it may also be necessary
to provide special environmental protection. Where the tariff system would
render a desirable development unviable or where the development
contributes to sustainable development in its own right, the tariff may be
reduced or waived. The Government therefore endorses a two-strand
approach.

6 However, our view is that whilst a two strand approach is probably

appropriate, the Government’s preferred option will not result in a simpler
system for developments with significant transport impacts because these
will inevitably involve negotiations about site-specific obligations. The
negotiated element would be informed by new Government guidance that
should reduce the scope for ambiguity and unfairness and increase
transparency. For the many more smaller developments, the Government’s
preferred option will increase development costs unless, as it proposes,
there is a threshold for exemptions. Such thresholds can create their own
problems (eg a concentration of proposals just below the threshold).
Furthermore, the cumulative impact of smaller developments on transport
systems far outweighs that of the much smaller number of larger ones. In
our view, the case for exemptions is therefore not proven.

7 We believe our approach could be applied to all development and that the
parking space tariff could be set so as not to inhibit development nor
significantly increase cost burdens on development relative to current
practice.

61