Permitted Development Rights (PDR) - review and extension: consultation analysis

5 Development Related to Active Travel

5.1 The final development type considered by the consultation paper was development related to active travel. The consultation paper set out specific proposals for the extension of PDR for storage sheds/structures for bikes in the front or side gardens of domestic properties, in private gardens of flats and within the grounds of offices, commercial and industrial buildings.

Extensions to PDR for storage sheds/structures for bicycles: houses

5.2 It is proposed to extend PDR to give all householders the right to erect bicycle/scooter stores up to a maximum size of 1.2 m height, 2 m width and 1.5m depth to the front of their properties. It is also proposed to increase the floorspace restriction for sheds in the rear gardens of houses in conservation areas to eight square metres, to allow for the storage of adaptive bikes and bike trailers as well as bikes and mobility scooters.

Q60. Do you agree with the proposal to allow the erection of a cycle store in the front or side garden of a house up to a maximum size of 1.2 metres height, 2 metres width and 1.5 metres depth?

Q60a. If you disagree, please explain why.

5.3 A total of 76 respondents answered the closed element at Question 60, including 26 organisation respondents and 50 individuals. Of these 76 respondents, 55 (72%) agreed with the proposal and 21 (28%) disagreed. Those disagreeing were five planning authorities, two third sector respondents, and 14 individuals.

Q60. Do you agree with the proposal to allow the erection of a cycle store in the front or side garden of a house up to a maximum size of 1.2 m height, 2 m width and 1.5 m depth?

Respondent type		Yes	No	Total
Organisations		19	7	26
% of organisations		73%	27%	100%
Public sector		9	5	14
	Planning authorities	9	5	14
	Other public bodies
Planning and other professionals		3		3
Private sector
	Digital telecoms
	Rural economy
	Other
Third sector		7	2	9
	Environment/natural heritage	2	1	3
	Community Councils/representative groups
	Other	5	1	6
Individuals		36	14	50
% of individuals		72%	28%	100%
All respondents		55	21	76
% of all respondents		72%	28%	100%

5.4 A total of 48 respondents provided written comment at Question 60, including all 21 of those who disagreed with the proposed change, 20 who agreed, and a further seven who did not answer the closed question.

5.5 Several respondents who agreed with the proposal observed that secure storage should encourage active travel and increase bike ownership, or that lack of suitable storage can be a barrier to some wishing taking up cycling. The contribution increased bike ownership could make to lowering car emissions and resulting positive impact on the environment was also highlighted

5.6 However, many of those providing comment raised concerns or suggested amendments to the proposal. The comments most frequently made related to the proposed size of a cycle store. Over half of those who disagreed with the proposal were of the view that the suggested size was inadequate or impractical. A number of those agreed with the overall proposal had similar reservations. The concerns of all groups fell into a number of broad categories, outlined below.

5.7 There was a general consensus that the proposed dimensions of 1.2 metre height, 2 metre width and 1.5 metre depth are insufficient. Reasons given were:

• More space is required to accommodate family storage of bikes, along with the associated bike equipment. This issue was raised by a Third sector Campaign group respondent and several individuals. The suggested dimensions were also considered inadequate for cargo bikes, adapted bikes and trailers.
• The height was specifically felt to be too low for many modern bikes, and it was also observed that most commercially available stores are higher than 1.2 metres whilst those within the 1.2 metres range are likely to have a slanted roof, which makes bike storage problematic.

5.8 The most frequently suggested alternative dimensions (again proposed by a Third Sector campaign group and often supported by individual respondents) were 1.5 metres height x 2.5 metres width x 1.2 metres depth. These measurements were noted to be based on guidelines considered acceptable for conservation areas by one planning authority and it was suggested a greater depth of store might be allowed for non-conservation areas.

5.9 Several respondents, including three planning authorities, commented on the potential negative visual impact on surrounding streetscape. This included concerns about the potential cumulative effect where there are a number of bike stores, in particular if there are no controls over the colours and materials used. It was suggested there could be a limit of one store per front garden, although also that households might want more than one store, for example if they have more than one e-bike. Advantages to the use of steel as a material for bike sheds, from a security aspect was also highlighted.

5.10 Planning authorities were also concerned about the potential for stores to block sightlines, resulting in safety issues for traffic and pedestrians. The proposed restriction that they must not compromise pedestrian or traffic safety was suggested to be difficult for householders to assess, and could result in enforcement action after bike stores were erected if sightlines were obscured.

5.11 Planning authority respondents also raised a number of concerns, or suggested alternatives to the proposals set out by the consultation document, as summarised below:

• How would it be possible to ensure that bike sheds are used solely for that purpose, rather than becoming a general store?
• Bike stores may result in increased on-street parking, resulting in tensions with policies that support off road parking.
• The ratio taken up by cycle stores should be linked to the overall size of the garden, to minimise impact.
• With respect to location of bike stores, the PDR should be framed to give a strong preference to the use of side or rear gardens wherever this is possible. One individual respondent suggested siting stores on the carriageway with a version of a resident’s parking permit.
• The present household PDR could be updated rather than creating a new one under ‘active travel’. Since the current household PDR allows for fences of up to only 1 metre, it was thought that higher structures under a new PDR might cause confusion.

5.12 Finally, one other public bodies respondent expressed concerns about the impact of cycle stores on non-designated buildings, conservations areas and listed buildings, whilst acknowledging that restriction on materials will help. It was observed that any work affecting listed building or structures within curtilage will require listed building consent.

Q61. Do you agree with the proposal to permit cycle stores up to 1.2 metres in height, 2 metres in width and 1 metre in depth in the front or side garden of a house in a conservation area?

Q61a. If you disagree, please explain why.

5.13 A total of 76 respondents answered the closed element at Question 61, including 27 organisation respondents and 49 individuals. Of these 76 respondents, 42 (55%) agreed with the proposal and 34 (45%) disagreed. Those disagreeing were 13 planning authorities, six third sector respondents, and 15 individuals.

Q61. Do you agree with the proposal to permit cycle stores up to 1.2 metres in height, 2 metres in width and 1 metre in depth in the front or side garden of a house in a conservation area?

Respondent type		Yes	No	Total
Organisations		8	19	27
% of organisations		30%	70%	100%
Public sector		1	13	14
	Planning authorities	1	13	14
	Other public bodies
Planning and other professionals		3		3
	Private sector
	Digital telecoms
	Rural economy
	Other
Third sector		4	6	10
	Environment/natural heritage	1	2	3
	Community Councils/representative groups		1	1
	Other	3	3	6
Individuals		34	15	49
% of individuals		69%	31%	100%
All respondents		42	34	76
% of all respondents		55%	45%	100%

5.14 A total of 56 respondents provided written comments at Question 61, including 33 who disagreed with the proposed change, 18 who agreed, and a further five who did not answer the closed question.

5.15 Consistent with the previous question, those who agreed with the proposal highlighted how bike stores could encourage more people to take up cycling, which would improve health outcomes and benefit the environment. Some individuals observed that permitting the erection of stores in conservation areas is essential, to allow equal access active travel for all, wherever they live. Other comments, from those agreeing and disagreeing with the proposal, raised concerns or suggested amendments.

5.16 Many of the points made echoed those at the previous question, with agreement on the principle of the proposal set alongside concerns about the practicalities. Some individuals again observed that the proposed dimensions are inadequate for the size and number of bikes that may require to be accommodated, in particular in family households and those with e-bikes, bike trailers, cargo bikes and similar.

5.17 Several individuals, third sector and campaign plus respondents suggested the alternative dimensions of 1.5 metre height, 2.5 metres width and 1.2 metres depth, measurements which some respondents observed are already used by one local authority, including in conservation areas. A small number of respondents proposed a depth of 1.5 metres.

5.18 A number of planning authorities were among the respondents who commented on the potential negative cumulative visual impact of bike stores on the character of conservation areas, with several observing that front gardens in conservation areas may be relatively small and/or have open frontages. Specific efforts may go into ensuring that these front gardens remain landscaped rather than, for example, being used for car parking. One planning authority expressed support for retaining the control planning permission currently gives them over the aesthetics within conservation areas.

5.19 Suggested revisions often focused on mitigating the potential impacts of bike stores on the character and nature of conservation areas including that:

• Guidance on colours and screening could lessen the visual impact of sheds and bring these in line with the look of the conservation area. Two respondents suggested that appropriate use of colour could be more important than size in limiting visual impact.
• Locating bike sheds only at the side or rear of properties would be less obtrusive.
• There should be restrictions on materials used. One planning authority observed that timber may not be the most suitable material in some conservation areas.
• A process of prior notification or prior approval should be used to control the siting and design of stores potentially allowing for larger sheds of up to 1.5 metre depth.

Q62. Should such an extension to PDR should be subject to a restriction on materials?

Q62a. Please explain your answer.

5.20 A total of 73 respondents answered the closed element at Question 62, including 25 organisation respondents and 48 individuals. Of these 73 respondents, 23 (32%) agreed that such an extension to PDR should be subject to a restriction on materials, and 50 (68%) disagreed. Those disagreeing were nine planning authorities, four third sector respondents, a planning professional, and 36 individuals.

Q62. Should such an extension to PDR should be subject to a restriction on materials?

Respondent type		Yes	No	Total
Organisations		11	14	25
% of organisations		44%	56%	100%
Public sector		6	9	15
	Planning authorities	5	9	14
	Other public bodies	1		1
Planning and other professionals		2	1	3
Private sector
	Digital telecoms
	Rural economy
	Other
Third sector		3	4	7
	Environment/natural heritage	2	1	3
	Community Councils/representative groups
	Other	1	3	4
Individuals		12	36	48
% of individuals		25%	75%	100%
All respondents		23	50	73
% of all respondents		32%	68%	100%

5.21 A total of 59 respondents provided written comments at Question 62, including 35 who disagreed with the proposed change, 21 who agreed, and a further three who did not answer the closed question. Many respondents used the opportunity to expand on observations they had made about the use of materials in the previous question. Other comments, from those agreeing and disagreeing with the proposal, raised concerns or suggested amendments.

5.22 Several respondents, predominantly planning authorities, observed that a ‘one size fits all’ approach is impractical, or that it would be difficult to apply a single set of design standards across different conservation areas. It was suggested that local flexibility will be required, supported by guidance setting out acceptable examples.

5.23 A number of respondents expressed the desire to see materials used to help manage visual impacts, to blend in with surroundings, or to preserve the character of conservation areas. It was also suggested that there should be restrictions and/or guidance on colour or that that colour could be more important than the materials used in terms of mitigating visual impact.

5.24 Several respondents commented specifically on the use of timber, including that:

• Vernacular finishes such as brick, stone or render could blend in more effectively than timber. One individual respondent supported the use of eco-friendly materials.
• Timber may vary in quality and that the use of poor quality materials such as chipboard could detract from character of a conservation area.
• Timber construction may not be secure enough for bike sheds, so steel may be more appropriate and is already used for many commercially available bike stores.
• Timber will not be suitable where non-combustibility of materials is important, including where sheds are located close to houses.

5.25 Some individual respondents argued that the PDR should be as permissive as possible, to encourage the move from car to cycle.

Q63. Do you agree with the proposal to increase the floorspace of storage sheds allowed in the rear garden of houses in conservation areas to 8 square metres?

Q63a. If you disagree, please explain why.

5.26 A total of 75 respondents answered the closed element at Question 63, including 25 organisation respondents and 50 individuals. Of these 75 respondents, 66 (88%) agreed with the proposal and nine (12%) disagreed. Those disagreeing were five planning authorities and four individuals.

Q63. Do you agree with the proposal to increase the floorspace of storage sheds allowed in the rear garden of houses in conservation areas to eight square metres?

Respondent type		Yes	No	Total
Organisations		20	5	25
% of organisations		80%	20%	100%
Public sector		8	5	13
	Planning authorities	8	5	13
	Other public bodies
Planning and other professionals		3		3
Private sector
	Digital telecoms
	Rural economy
	Other
Third sector		9		9
	Environment/natural heritage	3		3
	Community Councils/representative groups	1		1
	Other	5		5
Individuals		46	4	50
% of individuals		92%	8%	100%
All respondents		66	9	75
% of all respondents		88%	12%	100%

5.27 A total of 30 respondents provided written comments at Question 63, including eight who disagreed with the proposed change, 19 who agreed, and a further three who did not answer the closed question.

5.28 Consistent with responses to previous questions, those who agreed expressed the view that sufficient storage space is required for bikes, and the associated bike equipment, and that increasing the size of storage sheds in rear gardens will be less intrusive visually. Other comments, from those agreeing and disagreeing with the proposal, raised concerns or suggested amendments.

5.29 Respondents overall made fewer detailed comments at this question than others, but suggestions, often made by planning authorities, included that:

• This PDR should not apply to listed buildings.
• Prior notification/prior approval should be used to control design and location and to ensure sheds blend into the surrounding area.
• PDR for cycle sheds could be added as a separate class to the outbuilding already permitted.
• A restriction on the developable area should be included, similar to that for householders in non-designated areas, or that the maximum area of a shed should be linked to an agreed ratio of the footprint of the house and garden.
• It would not be possible to control the use of such stores for other purposes.
• Larger cycle stores will tend to have a higher roof apex and may be visible in rear gardens unless these are secluded. There is currently no proposal for restricting the height of the store which, it was suggested, should be limited to 3 metres.

5.30 In line with responses to previous questions, restrictions on materials/colour and best practice guidance on siting and design were also requested.

Extensions to PDR for storage sheds/structures for bicycles: flats

5.31 It is proposed to extend PDR to permit bicycle/scooter stores up to a maximum size of 1.2 m height, 2 m width and 1.5m depth to flats which have an allocated garden area, including in a conservation area.to the front of their properties. It is also proposed to introduce PDR to give flatted developments the right to erect a cycle store in the rear parking court or backcourt of a flatted block, of sufficient size to store two bikes per flat, including in conservation areas.

Q64. Do you agree with the introduction of PDR for the erection of a cycle store in the private garden area of a flat, including in a conservation area?

Q64a. If you disagree, please explain why.

5.32 A total of 78 respondents answered the closed element at Question 64, including 25 organisation respondents and 53 individuals. Of these 78 respondents, 68 (87%) agreed with the proposal and 10 (13%) disagreed. Those disagreeing were four planning authorities, two third sector respondents, and four individuals.

Q64. Do you agree with the introduction of PDR for the erection of a cycle store in the private garden area of a flat, including in a conservation area?

Respondent type		Yes	No	Total
Organisations		19	6	25
% of organisations		76%	24%	100%
Public sector		10	4	14
	Planning authorities	10	4	14
	Other public bodies
Planning and other professionals		2		2
Private sector
	Digital telecoms
	Rural economy
	Other
Third sector		7	2	9
	Environment/natural heritage	1	1	2
	Community Councils/representative groups	1		1
	Other	5	1	6
Individuals		49	4	53
% of individuals		92%	8%	100%
All respondents		68	10	78
% of all respondents		87%	13%	100%

5.33 A total of 46 respondents provided written comments at Question 64, including 34 who agreed with the proposed change, nine who disagreed, and a further three who did not answer the closed question. Those who agreed with the proposal reiterated many of the positive comments on the benefits of bike ownership given in previous questions. Many respondents were supportive of the proposal as it will provide some households living in flats the same access to cycle storage space as others. Other comments, from those agreeing and disagreeing with the proposal, raised concerns or suggested amendments.

5.34 However, a number of respondents, including several planning authorities, observed that allowing cycle stores in the private gardens of flatted accommodation could result in some adverse effects, as outlined below.

5.35 A planning authority, a third sector respondent and a planning professionals respondent all observed that there could be a negative impact on neighbours, and the potential for disputes where private gardens are adjacent to flats under different ownership. The proposed PDR could result in a bike store being built in front of the window of a separate owner.

5.36 Another planning authority observed that it may not be easy to define a private garden area separate from the wider amenity space for the flatted development and that some flatted developments have no defined garden ground.

5.37 Respondents also noted a number of concerns or suggested revisions that they would like to see including:

• Potential visual impacts in conservation areas were raised and, as at other questions, restrictions on materials and colour, and the need to observe best practice on design and siting were suggested.
• Prior notice/ prior approval was suggested both in conservation areas and for listed buildings.
• Several planning authorities commented that sheds should only be sited in a rear garden, with one recommending that there should only be one cycle shed per garden.
• A height restriction of 3 metres maximum was also recommended, and that sheds should not be visible from public roads.
• A third sector body proposed that the PDR should not apply to new build housing, but rather that cycle sheds in new developments should be subjected to the planning process to ensure high quality design standards.

Q65. Do you agree with the proposal to allow cycle stores sufficient to accommodate up to two bikes per flat to the rear of larger blocks of flats, including in conservation areas?

Q65a. If you disagree, please explain why.

5.38 A total of 78 respondents answered the closed element at Question 65, including 26 organisation respondents and 52 individuals. Of these 78 respondents, 60 (77%) agreed with the proposal and 18 (23%) disagreed. Those disagreeing were five planning authorities, four third sector respondents, and nine individuals.

Q65. Do you agree with the proposal to allow cycle stores sufficient to accommodate up to two bikes per flat to the rear of larger blocks of flats, including in conservation areas?

Respondent type		Yes	No	Total
Organisations		17	9	26
% of organisations		65%	35%	100%
Public sector		8	5	13
	Planning authorities	8	5	13
	Other public bodies
Planning and other professionals		3		3
Private sector
	Digital telecoms
	Rural economy
	Other
Third sector		6	4	10
	Environment/natural heritage	2	1	3
	Community Councils/representative groups	1	1	2
	Other	3	2	5
Individuals		43	9	52
% of individuals		83%	17%	100%
All respondents		60	18	78
% of all respondents		77%	23%	100%

5.39 A total of 44 respondents provided written comments at Question 65, including 22 who agreed with the proposed change, 18 who disagreed, and a further four who did not answer the closed question.

5.40 Those who agreed with the proposal welcomed the opportunity for access to bike storage for households living in flats.

5.41 Specifically with respect to the suggested provision of storage space for two bikes per flat, one third sector body agreed, although two others queried how this figure was decided on, and if there was any regional variation. Some respondents argued the proposed space to be insufficient as there could be a larger number of residents with bikes living in one flat, or residents might own several bikes. Some individuals suggested a quota of four bikes per property. Other respondents proposed that a figure could be based on, for example, the area of the flat, the number of bedrooms or the number of occupants.

5.42 However, planning authority and third sector respondents expressed concerns about the potential loss of amenity space if the PDR was implemented, with some respondents noting the COVID lockdown to have highlighted the importance of outdoor green space. To emphasise the potential impact, one respondent used an example of a tenement with 18 flats: under the proposed PDR this would result in storage spaces for 36 bikes, taking up recreational space and possibly impacting adversely on households in ground floor flats.

5.43 A planning authority highlighted the risk that residents may not all agree to the loss of garden space for bike sheds, leading to disputes between neighbours. They also suggested joint ownership to be an important issue that the proposed PDR would not take into consideration.

5.44 Limiting the proportion of green space that could be used for cycle stores was suggested including by using the prior notification/prior approval process to prevent excessive loss of green space. It was also suggested that prior notification/prior approval could also be used to limit the size or height of cycle stores in conservation areas and to ensure that designs did not have a negative impact on the conservation area.

5.45 Other points raised included that:

• There should be some flexibility on location since stores need to be easily accessible, secure and well-lit, which may not be the case at the rear of a block of flats.
• Provision of storage should be required for new flatted development, but adding stores to existing developments may reduce parking space and so cause increased on street parking.
• The definition of a ‘larger block of flats’ should be clarified.

Extensions to PDR for storage sheds/structures for bicycles: offices, commercial and industrial buildings

5.46 It is proposed to introduce PDR for secure, communal cycle stores in the curtilage of offices, commercial and industrial buildings. PDR would permit cycle stores of a size suitable to accommodate a number of bikes proportionate to the floorspace of the office.

Q66. Do you agree with the introduction of PDR to allow the erection of cycle stores for buildings of class 4, 5 and 6 uses?

Q66a. If you disagree, please explain why.

5.47 A total of 76 respondents answered the closed element at Question 66, including 27 organisation respondents and 49 individuals. Of these 76 respondents, 72 (95%) agreed with the proposal and four (5%) disagreed. Those who disagreed were a planning authority, a third sector respondent and two individuals.

Respondent type		Yes	No	Total
Organisations		25	2	27
% of organisations		93%	7%	100%
Public sector		13	1	14
	Planning authorities	13	1	14
	Other public bodies
Planning and other professionals		3		3
Private sector
	Digital telecoms
	Rural economy
	Other
Third sector		9	1	10
	Environment/natural heritage	3		3
	Community Councils/representative groups	1		1
	Other	5	1	6
Individuals		47	2	49
% of individuals		96%	4%	100%
All respondents		72	4	76
% of all respondents		95%	5%	100%

5.48 A total of 28 respondents provided written comments at Question 66, including 23 of those who agreed with the proposed change, four of those who disagreed, and one respondent who did not answer the closed question.

5.49 A number of respondents who agreed argued that secure cycle parking at workplaces should increase bike use by commuters, benefiting individuals’ health and helping the environment. One planning authority suggested that workplaces tend to be in commercial/industrial locations, where bike stores are likely to have less visual impact than they would do in residential areas.

5.50 However, some respondents were concerned about the potential visual impact or loss of amenity space, including in conservation areas, and proposed that a prior notification/prior approval process should be used in such instances. It was also suggested that the PDR should not apply in designated areas, with assessment on a case-by-case basis proposed within the curtilage of listed buildings or in conservation areas.

5.51 Other limitations proposed were that:

• PDR should not apply to cycle stores built on the public facing side of buildings, where there could be a disproportionate visual impact on the appearance of the local area. Two planning authorities raised this issue.
• Cycle sheds in new development class 4 – 6 buildings should be subjected to the planning process to ensure high quality design standards. This point was made by a third sector body.

5.52 Finally, concerns were expressed regarding potential loss of parking spaces, including where previous planning permission conditions may have set out minimum parking requirements. Since class 4 premises in particular might be located in town centres, it was suggested there should be clarity on where the PDR would apply.

Extensions to PDR for storage sheds/structures for bicycles: other locations

5.53 It is proposed that PDR should be introduced for the siting of up to four cycle stores of up to 1.36 metres in height, 2.55 metres in length and 2 metres in depth within a street block of 100 metres length in public places. The cycle stores should ideally be placed on the road carriageway (replacing car parking spaces other than disabled parking spaces as necessary) and should not reduce the width of the public footpath.

Q67. Do you agree with the introduction of PDR to allow the erection of cycle stores on-streets?

Q67a. If you disagree, please explain why.

5.54 A total of 78 respondents answered the closed element at Question 67, including 28 organisation respondents and 50 individuals. Of these 78 respondents, 69 (88%) agreed with the proposal and nine (12%) disagreed. Those disagreeing were four planning authorities, a planning professional, a third sector respondent, and three individuals.

Q67. Do you agree with the introduction of PDR to allow the erection of cycle stores on-streets?

Respondent type		Yes	No	Total
Organisations		22	6	28
% of organisations		79%	21%	100%
Public sector		11	4	15
	Planning authorities	10	4	14
	Other public bodies	1		1
Planning and other professionals		2	1	3
Private sector
	Digital telecoms
	Rural economy
	Other
Third sector		9	1	10
	Environment/natural heritage	3		3
	Community Councils/representative groups		1	1
	Other	6		6
Individuals		47	3	50
% of individuals		94%	6%	100%
All respondents		69	9	78
% of all respondents		88%	12%	100%

5.55 A total of 33 respondents provided written comments at Question 67, comprising 24 who agreed with the proposed change, eight who disagreed, and one who did not answer the closed question.

5.56 Some of those who agreed with the proposal pointed to the potential to increase provision for households living in flats and supported the reallocation of parking spaces in favour of cycle storage. Several respondents noted their approval for the current Edinburgh on street cycle storage scheme.

5.57 Other respondents were concerned about on street cycle storage in conservation areas or within the curtilage of listed buildings. Several planning authorities were among those who expressed a view that there should be no PDR for such stores in designated or conservation areas where, it was argued, prior notification/prior approval would be appropriate. It was noted Article 4 Directions could be applied by the planning authority, but with cost implications.

5.58 Issues related to pedestrian safety were also raised including that:

• The potential cluttering of streets may create inconvenience to pedestrians, and it was suggested sufficient space for pedestrians to pass without stepping onto road should be built into the PDR.
• Disabled access must not be compromised by restricted footways. The needs of people with visual impairment and those using wheelchairs were highlighted, and a third sector respondent suggested that cycle stores should be located away from pedestrian routes and designed using contrasting colours, to help those with sight issues.

5.59 A number of respondents commented on how the obligations of the roads authority would fit with the proposed PDR and concerns were expressed that a body other than the roads authority should be able to erect a structure that could adversely impact pedestrian and road traffic safety. It was suggested that any PDR should include a provision that the roads authority must be consulted.

5.60 It was also argued both that parking provision on a public road is already included in roads authority PDR, and that placing structures on the street already requires the agreement of the council as roads authority – thereby allowing the planning authority some control over such structures.

5.61 Some respondents took the view that planning authorities should be given the responsibility to for assessing on-street cycle stores through the current planning application process, or that planning authorities should be given guidance requiring them to support such applications.

5.62 Additional points raised included that:

• The Department of Transport has issued guidance on reducing security threats at rail, bus and coach stations. This would apply if the location of cycle stores was being considered above/near a subway or near a bus station.
• What constitutes a ‘street block’ should be clarified.
• Consultation with local residents and businesses should be required by the PDR, as streetscapes will be altered by on-street cycle stores.

Q68. If such PDR is introduced, do you agree with the proposed maximum size for the cycle stores, and the proposed restriction on the number allowed in a particular street or block?

Q68a. If you disagree, please explain why.

5.63 A total of 68 respondents answered Question 68, including 26 organisation respondents and 42 individuals. Of these 68 respondents, 35 (51%) agreed with the proposed maximum size and restriction on numbers allowed, and 33 (49%) disagreed. Those disagreeing were four planning authorities, three third sector respondents, and 26 individuals.

Q68. If such PDR is introduced, do you agree with the proposed maximum size for the cycle stores, and the proposed restriction on the number allowed in a particular street or block?

Respondent type	Yes	No	Total
Organisations	19	7	26
% of organisations	73%	27%	100%
Public sector	10	4	14
Planning authorities	9	4	13
Other public bodies	1		1
Planning and other professionals	3		3
Private sector
Digital telecoms
Rural economy
Other
Third sector	6	3	9
Environment/natural heritage	2	1	3
Community Councils/representative groups	1		1
Other	3	2	5
Individuals	16	26	42
% of individuals	38%	62%	100%
All respondents	35	33	68
% of all respondents	51%	49%	100%

5.64 A total of 44 respondents provided written comments at Question 68, comprising seven who agreed with the proposed change, 32 who disagreed and five respondents who did not answer the closed question.

5.65 Some of those who agreed and were positive about the PDR nonetheless made suggestions, including that the roads authority should be consulted and that there should be an assessment of whether the proposal would meet demand. Other comments, from those agreeing and disagreeing with the proposal, raised concerns or suggested amendments.

5.66 As with responses to previous questions, the flexibility to provide larger cycle stores was seen as necessary for families and those households requiring several of bike spaces. A number of respondents stressed that the storage space should be capable of accommodating e-bikes, cargo bikes and bikes with child seats.

5.67 Other respondents felt there should be no restriction on either the size of the cycle store or the number of stores, but rather that there should be facilities available for those bike owners who need them, just as provision is made for car owners. A number of respondents argued that restrictions on cycle stores should be matched by limitations on car parking on the street, as they considered this more visually intrusive than bike storage.

5.68 Respondents also suggested a number of other revisions to the proposals including that:

• The number of cycle stores should be determined by an assessment of local need, rather than being prescriptive, albeit that there could be limitations made by the dimensions and layout of a street. Several individuals and a third sector respondent made this point.
• Decisions on the size and number of stores should be taken by local planning authorities, rather than centrally dictated. Local control would enable current and future demand for cycle stores to be factored into planning and the most appropriate sizes and designs considered for each location.
• A number of different cycle store designs should be considered, with the Cyclehoops Bikehangar being only one option amongst a wider range of possibilities. It was argued that the consultation proposal would greatly restrict other design solutions.

Q69. If such PDR is introduced, do you think it should it be allowed in conservation areas and, if so, should it be subject to any other limitations on size, materials etc?

Q69a. If you disagree, please explain why.

5.69 A total of 70 respondents answered the closed element at Question 69, including 23 organisation respondents and 47 individuals. Of these 70 respondents, 49 (70%) agreed that PDR for on street cycle storage should be allowed in conservation areas, and 21 (30%) disagreed. Those disagreeing were 11 planning authorities, a planning professional, a third sector respondent, and eight individuals.

Q69. If such PDR is introduced, do you think it should it be allowed in conservation areas and, if so, should it be subject to any other limitations on size, materials etc?

Respondent type		Yes	No	Total
Organisations		10	13	23
% of organisations		43%	57%	100%
Public sector		2	11	13
	Planning authorities	2	11	13
	Other public bodies
Planning and other professionals		2	1	3
Private sector
	Digital telecoms
	Rural economy
	Other
Third sector		6	1	7
	Environment/natural heritage	2		2
	Community Councils/representative groups		1	1
	Other	4		4
Individuals		39	8	47
% of individuals		83%	17%	100%
All respondents		49	21	70
% of all respondents		70%	30%	100%

5.70 A total of 55 respondents provided written comments at Question 69, including 33 who agreed with the proposed change, 17 who disagreed, and five respondents who did not answer the closed question.

5.71 Several of those who agreed favoured introducing the PDR in conservation areas because these are often in located in urban centres and can usefully contribute to an overall reduction in car usage and the associated pollution. Consistent with the responses to other questions, it was also felt that the residents of conservation areas should be given an equal opportunity to benefit from cycle store provision.

5.72 However, some respondents, in particular planning authorities, were concerned about the potential negative visual impact of cycle stores on the character of conservation areas. One planning authority observed that this could be a particular issue for smaller conservation areas. Several respondents, including two third sector bodies, commented that similar rules should not be applied across different conservation areas and that local flexibility is needed.

5.73 Some respondents – largely planning authorities - preferred to see control retained via the planning application process. While planning authority and third sector respondents were among those who suggested using prior notification/ prior approval to prevent negative impact on the amenity value of conservation areas by controlling the design of stores, the materials and colours used, and their location.

5.74 There was agreement across a range of respondents that there should be restriction on the materials, colours and designs used in conservation areas, to ensure these are sympathetic to their local surroundings. One respondent suggested that design guidance could be produced to help with this.

Q70. Is there any other amendment to the General Permitted Development Order that you think we should consider in order to encourage active travel further?

5.75 A total of 29 respondents provided comment at Question 70, including 14 organisation respondents and 15 individuals. Organisation respondents included four planning authorities, an other public bodies respondent, six third sector respondents, and three planning professionals.

Q70. Is there any other amendment to the General Permitted Development Order that you think we should consider in order to encourage active travel further?

Respondent type		Answered	Not answered	Total
Organisations		14	47	61
% of organisations		23%	77%	100%
Public sector		5	17	22
	Planning authorities	4	12	16
	Other public bodies	1	5	6
Planning and other professionals		3	2	5
Private sector		0	14	14
	Digital telecoms		5	5
	Rural economy		3	3
	Other		6	6
Third sector		6	14	20
	Environment/natural heritage	3	6	9
	Community Councils/representative groups	1	3	4
	Other	2	5	7
Individuals		15	43	58
% of individuals		26%	74%	100%
All respondents		29	90	119
% of all respondents		24%	76%	100%

5.76 Points not already covered elsewhere in this section are outlined below.

5.77 Several respondents commented on the need for an inclusive approach to active travel that considers the needs of the elderly and people with disabilities so that they are not disadvantaged, for example by not being able to use bike stores because the sizes are inadequate for adapted bikes, or if disabled parking is lost. It was recommended that the evaluation of any active travel project should include an Equalities Impact Assessment.

5.78 It was observed that the PDR proposals only relate to cycling, despite the definition of active travelling being much wider, including walking and wheeling. It was suggested that there is scope for PDRs to support active travel more generally, for example through investment in developing green infrastructure, expanding paths networks and the design/redesign of the built environment to encourage people outdoors and into natural surroundings.

5.79 There were also suggestions for specific PDR proposals, set out below.

• The structure to support bike hire schemes, including hire points and docking points.
• Hubs for the hire or communal use of cargo bikes, including in conservation areas.
• Cycle storage made available in public locations, such as shopping centres, stations, and ferry terminals. These could include public bike repair stations.
• A PDR for the development of e-bike charging hubs/points.
• The development of rural paths, using a PDR to simplify the process of setting these up.