Template text for comments
Please review and complete highlighted sections. Sign at the end with your name, address and postcode to ensure your comments are accepted as valid.
Copy + paste into an e-mail and send to: planning@manchester.gov.uk
Subject: Comment on Planning Application 142888/FO/2025
Dear Manchester Planning team,
I am writing to lodge an objection to planning application 142888/FO/2025 – Cambridge Halls Of Residence Cavendish Street Manchester M15 6TT.
My primary objection is that the proposals have been designed to deter cyclists from using the safest and most direct route through the site. This route has been open to cyclists ever since the road was first built; it is an essential, well-used part of the city’s cycling network and therefore the proposal to deter and/or divert cycles away from Cavendish Street is directly at odds with Manchester City Council’s planning, sustainability and transport policies.
[INSERT HERE OR DELETE THIS SECTION describe your own experience of using Cavendish Street, as a pedestrian, cyclist or other road user. Do you live or work nearby or use the route regularly? What difference has this active travel route made to your life? How would you be impacted if it were removed?]
The applicant has also made misleading claims regarding the road’s legal status and regarding pedestrian safety which I will outline below.
I am asking that the council refuse this application, and invite the developer to come back with a proposal that maintains direct cycle as well as pedestrian access along Cavendish Street, designed to modern standards set out in Greater Manchester’s Streets For All design guide and in Department for Transport guidance note LTN 1/20. I am sure that the Highways team at MCC and the Active Travel team at TfGM will, if asked, be happy to comment on how such a route could be provided within the space available.
I am also asking that the council make a Section 106 agreement (s106) with the applicant to fund safety improvements for pedestrians and cyclists at the junction of Cavendish Street and Higher Cambridge Street – the applicant themselves discuss the shortcomings of the existing junction layout in Section 4.2.1 of the Transport Statement (“Cyclists have also been observed to queue on the footway to gain direct access to the Higher Cambridge Street/Cavendish Street junction (via a gap in the guard railings) rather than following the road markings which advise cyclists to dismount and use the controlled pedestrian crossings”). The improvements might take the form of a CYCLOPS junction. CYCLOPS is a homegrown Greater Manchester innovation now frequently used on Highways schemes across the country to deliver safe pedestrian and cycle movements without undue impact on traffic flows.
For prospective occupants and passers-by alike, in line with the S106 tests as set out in Paragraph 58 of the National Planning Policy Framework (NPPF) 2024, a contribution to junction safety improvements improvement would be ‘necessary to make the development acceptable in planning terms’ (by contributing to an appropriate movement strategy for the site), ‘directly related to the development’ (given its proximity, the pressure added to the junction by the proposed threefold increase in residents, and in light of the wholly inadequate mitigation route proposed by the applicant), and ‘fairly and reasonably related in scale and kind to the development’ (given the stated threefold increase in residents explained by the applicant, so directly adding more pressure to the junction).
1 Legal Status of Cavendish Street
This section of Cavendish Street, an adopted Highway, was subject to a stopping up order dated 14.06.1996. That order required that “the Developer shall provide a new highway which shall be a footpath/cycleway”. MMU have since installed physical signage stating that Cavendish Street “has not been dedicated as a Highway” and have bolted down uncomfortable and restrictive speed bumps across the route in an apparent attempt to dissuade cyclists from exercising their legal rights over this space. Both measures may be unlawful, as my understanding is that cyclists do retain a legal Right of Way along Cavendish Street, unchanged from when the entire road was an adopted highway, and the speed bumps are inaccessible to some Disabled users.
2 Cycling routes and planning policy
The case for walking and cycling and specifically for maintaining and improving high quality cycling networks is clear at every level of modern planning policy, including:
- NPPF 2024’s “vision-led approach”
- LTN 1/20
- Places For Everyone Joint Development Plan Objectives 6, 7 and 10
- Places for Everyone Joint Development Plan policies JP-Strat14, JP-C1, JP-C5 and JP-C6
- GM Transport Strategy 2040 and the “Right Mix” targets
- Greater Manchester Streets for All strategy and Streets for All design guide
- Manchester City Council’s Active Travel Strategy
- Manchester City Council’s commitment to be a Zero Carbon city by 2038
The policy position is absolutely clear – changes to the existing road and cycle networks should make cycling more convenient for people, not less convenient.
This specific stretch of Cavendish Street is a key part of the existing cycle network. It appears on TfGM’s Bee Network map as a Beeway (“the routes that get people from A to B … representing the most direct routes between crossing points.”) and connects to the Stretford Road Busy Beeway (“corridors or crossing points on busier roads that will require a higher level of design intervention to improve cycling and walking.”) It is also mapped on the TfGM Cycle Network.
The national standard for cycling infrastructure is DfT guidance note LTN 1/20. LTN 1/20 advises above all else that cycle routes and networks should be Safe, Direct, Comfortable, Attractive and Coherent. Introducing unnecessary diversions, junctions and bends into a well-used existing route undermines all of these core principles, resulting in a lower quality cycle network which will make it harder for the council to achieve its cycling objectives.
The applicant has offered various reasons why diverting cyclists is necessary but all of these reasons seem to be either existing problems, or problems designed into the scheme. The proposal is to demolish and redevelop the site – so considerations like limited space and the placement of entrances, shop frontages, planting and pedestrian areas are entirely within the applicant’s scope to manage. Instead of starting with the problem “there is an existing busy cycle route across this site, how can I design to accommodate everyone’s needs?”, it seems the applicant has started with the conclusion “cyclists must be deterred” and instructed their consultants to post-rationalise that decision.
3 Misleading claims regarding safety
Page 22 of the Design & Access Statement refers to the “existing controversial link along Cavendish St., which is resulting in collisions of pedestrians, electric scooters, cyclists, etc.”
However the map of recorded collisions, on page 18 of the Transport Statement submitted in the same planning application, shows no recorded collisions whatsoever on this link, only on the adjacent main roads.
It appears the applicant is attempting to restrict cycle access based on a “problem” for which they have no evidence.
Yours sincerely,
NAME
ADDRESS
POSTCODE
Plain Text Version:
Dear Manchester Planning team,
I am writing to lodge an objection to planning application 142888/FO/2025 – Cambridge Halls Of Residence Cavendish Street Manchester M15 6TT.
My primary objection is that the proposals have been designed to deter cyclists from using the safest and most direct route through the site. This route has been open to cyclists ever since the road was first built; it is an essential, well-used part of the city’s cycling network and therefore the proposal to deter and/or divert cycles away from Cavendish Street is directly at odds with Manchester City Council’s planning, sustainability and transport policies.
The applicant has also made misleading claims regarding the road’s legal status and regarding pedestrian safety which I will outline below.
I am asking that the council refuse this application, and invite the developer to come back with a proposal that maintains direct cycle as well as pedestrian access along Cavendish Street, designed to modern standards set out in Greater Manchester’s Streets For All design guide and in Department for Transport guidance note LTN 1/20. I am sure that the Highways team at MCC and the Active Travel team at TfGM will, if asked, be happy to comment on how such a route could be provided within the space available.
I am also asking that the council make a Section 106 agreement (s106) with the applicant to fund safety improvements for pedestrians and cyclists at the junction of Cavendish Street and Higher Cambridge Street – the applicant themselves discuss the shortcomings of the existing junction layout in Section 4.2.1 of the Transport Statement (“Cyclists have also been observed to queue on the footway to gain direct access to the Higher Cambridge Street/Cavendish Street junction (via a gap in the guard railings) rather than following the road markings which advise cyclists to dismount and use the controlled pedestrian crossings”). The improvements might take the form of a CYCLOPS junction. CYCLOPS is a homegrown Greater Manchester innovation now frequently used on Highways schemes across the country to deliver safe pedestrian and cycle movements without undue impact on traffic flows.
For prospective occupants and passers-by alike, in line with the S106 tests as set out in Paragraph 58 of the National Planning Policy Framework (NPPF) 2024, a contribution to junction safety improvements improvement would be ‘necessary to make the development acceptable in planning terms’ (by contributing to an appropriate movement strategy for the site), ‘directly related to the development’ (given its proximity, the pressure added to the junction by the proposed threefold increase in residents, and in light of the wholly inadequate mitigation route proposed by the applicant), and ‘fairly and reasonably related in scale and kind to the development’ (given the stated threefold increase in residents explained by the applicant, so directly adding more pressure to the junction).
1 Legal Status of Cavendish Street
This section of Cavendish Street, an adopted Highway, was subject to a stopping up order dated 14.06.1996. That order required that “the Developer shall provide a new highway which shall be a footpath/cycleway”. MMU have since installed physical signage stating that Cavendish Street “has not been dedicated as a Highway” and have bolted down uncomfortable and restrictive speed bumps across the route in an apparent attempt to dissuade cyclists from exercising their legal rights over this space. Both measures may be unlawful, as my understanding is that cyclists do retain a legal Right of Way along Cavendish Street, unchanged from when the entire road was an adopted highway, and the speed bumps are inaccessible to some Disabled users.
2 Cycling routes and planning policy
The case for walking and cycling and specifically for maintaining and improving high quality cycling networks is clear at every level of modern planning policy, including:
NPPF 2024’s “vision-led approach”
LTN 1/20
Places For Everyone Joint Development Plan Objectives 6, 7 and 10
Places for Everyone Joint Development Plan policies JP-Strat14, JP-C1, JP-C5 and JP-C6
GM Transport Strategy 2040 and the “Right Mix” targets
Greater Manchester Streets for All strategy and Streets for All design guide
Manchester City Council’s Active Travel Strategy
Manchester City Council’s commitment to be a Zero Carbon city by 2038
The policy position is absolutely clear – changes to the existing road and cycle networks should make cycling more convenient for people, not less convenient.
This specific stretch of Cavendish Street is a key part of the existing cycle network. It appears on TfGM’s Bee Network map as a Beeway (“the routes that get people from A to B … representing the most direct routes between crossing points.”) and connects to the Stretford Road Busy Beeway (“corridors or crossing points on busier roads that will require a higher level of design intervention to improve cycling and walking.”) It is also mapped on the TfGM Cycle Network.
The national standard for cycling infrastructure is DfT guidance note LTN 1/20. LTN 1/20 advises above all else that cycle routes and networks should be Safe, Direct, Comfortable, Attractive and Coherent. Introducing unnecessary diversions, junctions and bends into a well-used existing route undermines all of these core principles, resulting in a lower quality cycle network which will make it harder for the council to achieve its cycling objectives.
The applicant has offered various reasons why diverting cyclists is necessary but all of these reasons seem to be either existing problems, or problems designed into the scheme. The proposal is to demolish and redevelop the site – so considerations like limited space and the placement of entrances, shop frontages, planting and pedestrian areas are entirely within the applicant’s scope to manage. Instead of starting with the problem “there is an existing busy cycle route across this site, how can I design to accommodate everyone’s needs?”, it seems the applicant has started with the conclusion “cyclists must be deterred” and instructed their consultants to post-rationalise that decision.
3 Misleading claims regarding safety
Page 22 of the Design & Access Statement refers to the “existing controversial link along Cavendish St., which is resulting in collisions of pedestrians, electric scooters, cyclists, etc.”
However the map of recorded collisions, on page 18 of the Transport Statement submitted in the same planning application, shows no recorded collisions whatsoever on this link, only on the adjacent main roads.
It appears the applicant is attempting to restrict cycle access based on a “problem” for which they have no evidence.
Yours sincerely,
NAME
ADDRESS
POSTCODE