National Planning Policy Framework Forensics #27 Transport Assessment

The draft contains a new section on Transport Assessments, the current PPG13 references to assessments and the good practice guide on assessments are principally concerned with process, whereas the new section is a new statement of policy.

Planning applications for all developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. In determining applications local authorities should consider whether:
• the opportunities for sustainable transport have been taken up given the nature and location of the site;
• safe and suitable access to the site can be achieved for all people;
• improvements can be undertaken within the local highway network that limit the significant impacts of the development and, subject to those considerations, not refuse planning permission on transport grounds unless the residual impacts of development are so severe that planning permission should not be granted having regard to the need to encourage increased delivery of homes and sustainable economic development.

This poorly drafted section does much to undermine transport policy.

  • ‘development that generates significant amount of movement’  – you mean nightclubs?  What nonsense.  I much prefer the crystal clear wording from Scottish Policy:

 A Transport Assessment will be required where the development or redevelopment is likely to have significant transport implications, no matter the size. The coverage and detail of the Transport Assessment should reflect the scale and the likely extent of transport impacts of the proposed scheme.

The Scottish and emerging Welsh guidance are well in advance of English practice, avoiding the confusion between statements and assessments simply requiring a detailed treatment in some cases, and in Scotland much less if a scheme has been assessed as part of the plan making process.  This integrated system should be adopted in England.

  • The first bullet point implies that if a site is remote with no opportunities for sustainable transport then  it is acceptable.
  • The second bullet is unobjectionable as far as access to the site is concerned but a key aspect of transport planning is that safe and suitable access within a site is secured, both to the front entrance of a single buildings and in providing safe and walkable neighbourhoods for larger schemes.  The old fashioned approach that saw transport planning end at the site entrance was, one hoped, almost superseded.
  • The third bullet reads like it was written by a developer to ensure that a scheme could never be refused on transport impact grounds.  It only looks at the local highway network, so impact in strategic roads and motorways would not be considered.  The ‘so severe’ test is excessively strict and will cause endless argument on appeal.  The last part of the sentence is ambiguous, it could be read as implying that the need for growth overrides transport issues.  But it could also be read as stating that it could undermine the provision of other housing or employment schemes and should be refused.  This is the key issue, if you allow one scheme to unacceptably eat into transport capacity it robs it from all others, and other schemes more reliant on sustainable transport can generate more houses and jobs over a plan period.  The wording conflicts with the ‘balance’ test used in National Policy Statements re transport impacts i.e.”The decision maker should not grant consent to schemes where the adverse impacts after mitigation outweigh the benefits.’
I would suggest the following rewording, which also removes the need for several para on page 23:

A Transport Assessment (including a travel plan) will be required where the development or redevelopment is likely to have significant transport implications. The coverage and detail of the Transport Assessment should reflect the scale and the likely extent of transport impacts of the proposed scheme.

Plans should aim for a balance of land uses within their area so that people can be encouraged to minimise journey lengths for employment, shopping, leisure, education and other activities. They should focus mixed use development involving large amounts of employment, shopping, leisure and services in town centres & encourage a mix of land uses, including housing, in town centres and at a neighbourhood scale.

The decision maker should consider whether a development or a proposed allocation:

  1. Is located and designed to minimise the need to travel, and the number and length of car journeys – including whether the location is appropriate to the transport networks serving it given the size and nature of the use. Schemes attracting or generating significant numbers of people should be located and designed to maximise use of high quality sustainable transport networks, expanding them where needed. Schemes attracting significant number of freight movements should be located close to junctions of the main road networks, and for bulky freight take reasonable opportunities for rail or water movement. The differing circumstances of urban and rural areas should be considered.
  2. Provides safe and suitable access to and within the site for the whole community. This means prioritising walking and cycling – minimising conflict with cars and large vehicles, & promoting walkable and connected communities with, where practical, accessible key facilities (primary schools, local shops and healthcare) especially within large scale developments
  3. Leaves sufficient capacity so that, after any improvements to transport networks , any residual impact would not unacceptably harm the functioning of the network or unacceptably harm the ability to deliver sustainable growth in the wider area.
  4. Has proper servicing and emergency access, and facilities for charging electric and other low emission vehicles.

The needs of travellers should be considered across the whole journey, from origin to destination, with special emphasis on those with mobility restrictions such as disabled people, the elderly and those with children.

30 Cubic Miles of Oil Left

We use as a planet about 1 cubic mile of oil a year. We have about 40 years left (from proven reserves) at current rates of consumption but with increasing rates of consumption it could be 30.

Of course there are undiscovered reserves but they are likely to be very expensive, in remote areas and deep seas. Of course as we get close prices go up so extending the life of oil left, but again prices are pushed up. Global oil production has now reached a plateau and is expected to decline from around about 2020.

Replacing oil would require about 60,000 large windturbines a year over 20 years.

The future will be expensive for the energy poor.

Number 10’s Open Aim to Destroy the Planning System

From Chris Brown’s Blog in Regeneration.

There was a fascinating breakfast this week organised by Dermot Finch at Fishburn Hedges with James O’Shaughnessy the Director of Policy at 10 Downing Street.

James is a Policy Exchange alumnus and lead advisor on CLG issues….

The starting point is the idea that Localism is about Growth which is best driven from the bottom up (although local communities will only be ‘allowed’ to add extra development).

His view on the proposed Use Classes Order change to allow business premises to become housing was that it would have little impact on business rents. He blamed institutional investors for their upward only rents and felt that only the less efficient business buildings would disappear.

On town centre first policies he advocated building where it is cheapest and profits are greatest and was of the view that John Lewis should have gone into Westfield. He felt brownfield targets were a mistake and that urban areas should grow outwards.

Describing CLG as 3000 planners with a culture of drawing masterplans he contrasted the planning system with his preference for a system where development decisions were dependent on market pricing. While the Government had continued with the planning system they were philosophically libertarian and communitarian. Local Government’s role was guiding where to build not whether or what to build.

James O’Shaughnessy is special advisor to the PM at 10, Jamie Hilton is head of the no 10 policy unit who holds similarly extreme views. James doesnt seem to realise that both Westfields in London are on the edge of town centres and in being located so are leading to enormous regeneration of those centres.

These extreme views are fully in line with the Policy Exchange and those associated with them, including their director Alex Morton who this week said

‘Given that developers build homes because there is demand, a planning application is proof of demand. So we should require councils to scrap the “predict and provide” model that invariably underestimates demand.’

The Policy Exchange is member of the European Wide network of right wing think tanks The Stockholm Network, which has close links to climate change deniers, and it has links to the Heritage Foundation, The Competitive Enterprise Institute and the Cato Institute and receives funding from firms such as Exxon Mobil as well as many big pharma firms. This web of ‘think tanks’ conceal their funding links and promote the removal of almost all forms of environmental regulation. See here

They are dangerously close to the ideas of the tea party anti-sustainable development brigade, differing only giving lip service to sustainable development (by defining it away)

There appears to be a struggle between number 10 and Bressingdon Place. The only difference being that Bressingdon wants to maintain some limited role for the local plan and design control.

But as John Howells MP, author of Open Source Planning and PPS to Greg Clarke, said in Feb if no up to date local plan a developer could then build ‘what they like, where they like and when they like’ which one property magasine rightly called a ‘developers charter’

It is time people woke up. The practitioners draft of the NPPF was shocking, full of all sorts of quiet policy shifts such as removing the protection of the countryside for its own sake, but once it gets into 10s hands, and Eric Pickles who wants to reduce it to 10 pages, it will say little more than say yes yes yes. Whilst the revolt of the nurses etc shocked the government they will be shocked by the revolt of the CPRE, The RSPB (with more members than all political parties combined) etc once they get their letter writing to mps going fearing sprawl everywhere. Its politically stupid as the opposition will capitalise as a concern of the shires and tactically stupid, as with Patrick Jenkins proposal to dismantle the Green Belt in 1980 it will lead to overreaction in the other direction leading to less development when we need more. It is not like there hasnt already been lots of u-turns in this field.

Chris there is a solution to either sprawl or over tight green belts – its unfashionable but its called regional planning and new towns – see here

I don’t think Bressingdon Place has 30 planners, and I im pretty sure none of them will have ever done a masterplan mores the pity.

Decision Theory for Planners #113 To decide or not to decide? – the Delay Dilemma

When it is not necessary to make a decision, it is necessary not to make a decision.” ~ Lord Falkland 

“A good plan, executed now, is better than a perfect plan next week.”
– General George S. Patton, Jr.

The issue of when to take a decision has generated very little literature.  It is an almost unexplored area.

The above two quotes show two sides of the delay dilemma.  For Falkland the risks of deciding now outweighs the benefits.  Better information, or changed circumstances make deciding now risky.  For Patton the risks of waiting outweighs the benefits, we might have good understanding of the situation now, but not in the future, by when circumstances might not be in our favour.  Patton of course was one for putting the other side on the back foot, with his nostrom of ‘attack is the best means of defence’.

We then seem to have two factors that weigh on the issue of the meta-decision, that is how, when and why we make a formal decision.  How fast circumstances are changing and the quality of our information and the perception of how this may change in the future.

You might think then that a simple approach of rational certainty.  I.E a  two factor optimisation model would suffice of the form of:  If the benefits of making one of two or more options now outweigh the uncertainties and dis-benefits of making the decision in the future then make the decision.

Such a theory though does not stand up to serious thought.

When we make a meta-decision to decide we are making two decisions, to decide and the choice we decide. when we make a meta-decision not to decide we make only one.

The rational certainty approach does not stack up because the decision to decide and the choice we make are always and indivisibly one decision.  We decide because our choice and its risks have advantages to the staus-quo ante when projected forward, even where projected forward one infinitesimally small division in time.

Where we cannot decide it is either because the uncertainties of delay outweigh the advantages of delay or we are struck by geniune indecision between two or more choices and are seeking resolution of those choices.

Meta-decisions therefore have a fundamental antisymmetry in time compared to other decisions.  Indeed the uncertainties associated with meta-decisions seem to dominate the public policy process.

What is more because the future is fundamentally unknowable rational ignorance is essential for making a decision at all.  As you can always seek out more information it might seem more rational to delay, but that delay has an opportunity cost in terms of future information seeking yourself or from others.

A decision to decide is effectively saying to yourself I cant predict the future but im going to make an assumption that the future will not be significantly divergent from the future I have mentally projected.  That is the future will not be surprising.

If though that future is surprising to someone else we may have an advantage over them, particularly in terms of economic advantage.  Seen in this way it supports GLS Shackles view that economic decisions are made in terms of assessment of competing degrees of potential surprise, and that decision making is a creative act in terms of how we shape the future.

As well as not being able to disentangle a meta-decision of yes from a decision we cannot disentangle such decisions from other actors.

“In some negotiations, the tactic of one side might be to delay negotiations indefinitely. For example, environmentalists can often discourage a developer through protracted litigations.” — Howard Raiffa, in The Art and Science of Negotiation, 1982

A decision space is not just defined by the actor making the decision but those who supply information and can react to a decision seeking to overturn it or by supplying information in the hope that the decision is delayed.  Such examples are legion in planning.

Strategic delays are often used by disputants who do not have the power to win directly in court or through procedure.  Rather than waste their resources on a fight they cannot win, some use delaying tactics to frustrate their opponent hoping that circumstances turn in their favour, such as a change in national policy. If a group is part of the decision-making process but does not want change, the slower the process, the better. If they do not have a say in the design of the process, then they can deliberately delay it by stalling on their involvement.

Most recently the crackdown on corruption in India has become so great that civil servants are trying to prevaricate on all decisions by giving excessive briefing notes to ministers because they know that all decisions will subject them to scrutiny whether innocent or not.

Also complex decisions are interconnected, often part of a social mess, so we are often left in a position of a possibly infinite regress of not being able to decide one thing without deciding everything.  This might seem rational looking at individual widenings of the decision space but overall the dis-benefits, of a decision being delayed exponentially, force a cut of in terms of the scope of the expected interconnected impacts of our decisions.

The final problem with rational certainty is that the vast majority of decision made are not made on the basis of assessment of more than one option.

Gary Kein’s research, set out in his book ‘Intuition at Work: Why Developing Your Gut Instincts Will Make You Better at What You Do (2002) derived from his work in the US miltary on how commanders make decisions.

He found that 95% of decsions are made without options, without concious consideration of evidence, they were made on instinct.  This led him to wonder, with only one option waht was the decision compared to?

He believes that a given situation, the decision maker will pick up cues and indicators that let them recognise patterns. Based on these patterns and the decision they have to make, the person chooses a single course of action, an ‘ action script‘, that they consider will achieve the outcome – they ran a mental simulation.

The mental simulation was based on mental models that the decision maker had developed through experience. In other words, the decision maker has an idea how things work based on the knowledge that has been gained from experience. S/he compares the option against what is known to work.

This is intuitively correct.  Inexperienced planners will often be paralysed by the need to seek more evidence and the choice of options, experienced planners will often leap to a conclusion and then either seek evidence to support it or disprove it. As people become more expert in their chosen field, as they have more and more experience, their ability to recognise patterns is enhanced. This gives them more options to choose from. Which means that, more often than not, the first option they choose will work.

If the decision maker considers the action script will achieve the outcome, they go ahead.

If they consider that it might not work because of a potential problem, they may try and alter the action script in some way. If mentally they don’t think it will work, they discard it completely, and choose a second action script.

This is then mentally rehearsed and so on until they find an action script that they think will work. This is then utilized. Note that in this recognition primed decision making model there is no comparison of alternatives.  If this pattern is used often then the decsion can be routinized. Routinized decisions can also be instituationalised as policy, indeed this is the source of policy that works, based on expereince of achieving successful outcomes.

This theory is very similar to Gerd Gigerenzers ideas of gut instincts we met in the first part of this series.

How China’s Cheap Oil Imports fuels its growth

One of the key problems for Chinas economy is its shortage of oil and its reliance on coal.

China became a net importer of crude oil in 1993.China’s oil dependency reached 45 percent in 2006 and has grown at two percent every year after that.

China is the world’s second-largest oil importer, behind the USA.

Unlike the US it has not previously built up strategic reserves, it is only now doing so and this will not be completed until 2020.  It has never experienced an oil supply shock before and the concerns over the Arab spring disruptions has exposed its vulnerability (although only 3% of Libya’s exports of oil were to China).

Analysts believe that by 2020, nearly 65 percent of the oil consumed in China will have to be imported.

Hence the States focus on rail and not freeways as an optimum transport solution. It realises that mass car-ownership on an american scale would bankrupt it because of the export-land effect.

None the less its growth is inevitably fuelling demand for oil, 60% of which is used by vehicles, so how does it secure its supplies?

China imported a total 203.8 million tons of crude oil in 2010, up 13.9% from 2009.

The follow data of oil imports by country.

  • Saudi Arabia … 5.7 million barrels, up 15.1% from 2009 (20.5% of total)
  • Angola … 4.4 million barrels, up 7.6% (15.8% of total)
  • Iran … 3.2 million barrels, up 8.6% (11.4% of total)
  • Russia … 2.1 million barrels, up 31.5% (7.5% of total)
  • Sudan … 1.7 million barrels, up 16.1% (6% of total)
  • Oman … 1.6 million barrels, down 19.5% (5.8% of total)
  • Iraq … 977,190 barrels, up 285.1% (3.5% of total)
  • Kuwait … 965,279 barrels, up 20% (3.5% of total)
  • Libya … 865,557 barrels, up 98.9% (3.1% of total)
  • Kazakhstan … 819,389 barrels, up 5.9% (2.9% of total)
  • Venezuela … 718,523 barrels, down 18.5% (2.6% of total)
  • Republic of Congo … 557,931 barrels, down 6.5% (2% of total)
  • Brazil … 553,574 barrels, up 34.3% (1.99% of total)
  • United Arab Emirates … 451,163 barrels, down 27. 8% (1.6% of total)
  • Indonesia … 441,256 barrels, up 132.3% (1.59% of total)

We know a number of these arrangement are below world market price.

Iran nominally exports oil to China at market price however with $60 of Chinese investment in increasing capacity in Iran since 2008 China effectively gets a major subisdy through being able to take the refining cut.  Its long terms deals (25 years) are undoubtedly at a discount.  nAcoording to the Middle Eastern Policy Council

if you convert natural-gas reserves into barrels of oil equivalent (boe), Saudi Arabia has 302.5 boe, and Iran has 301.7 [reserve supplies]. Russia’s hydrocarbon reserves, the world’s third-largest, are 198.3 boe. This means Iran’s hydrocarbon resources are almost equal to those of Saudi Arabia and much greater than those of Russia. What makes Iran’s future energy potential even more impressive is the fact that, in contrast to its vast reserves, Iran’s extraction rate is relatively low. Given the proper amount of investment and technology, Iran would have the capacity to boost its production substantially and become an even larger provider of energy for China.

As for Angola Beijing secured a major stake in future oil production in 2004 with a $2 billion package of loans and aid that includes funds for Chinese companies to build railroads, schools, roads, hospitals, bridges, and offices; lay a fiber-optic network; and train Angolan telecommunications workers.

China gets oil from Russia  at about $60 per barrel, less than half the current global price.  Many of the Siberian oilfields are remote from the sea and piping through China gives them a monopolistic position, able to dictate price.

It also get below market price oil from Venezuela in return for a $20 billion investment. According to the Energy Tribune, the Chinese secured deals throughout Latin America in 2010 worth at least $65 billion in stakes of projects that could eventually produce over 1.3 million barrels of crude oil a day.  Chavez has on several occasions threatened to cut off all oil exports to the US – which gets 10% of its oil from Latin America.

The need to secure foreign reserves undoubtedly impacts on its foreign policy, with it for example unwilling to impose sanctions on Sudan or Iran.  The US is equally if not more vulnerable, being being a democracy cannot afford such a ruthlessly selfish policy.  As the MEPC concludes

According to some scholars, there is an emerging “axis of oil” constituting Russia (a major producer), China (a growing consumer) and the nationalist oil-producing states (most notably, Iran, a major producer). Their interests converge, and they are now challenging U.S. hegemony on a wide range of issues globally

New sources of oil from Africa and South America will not come on stream for some time, and in the meantime China has to compete on the global market.  For the time being the proportion of Chinas oil imports secured below world market prices is small, but will grow over time.  China has lacked expertese in this field so has conducted much of its negotiations with Petronas, controlled by the Malaysian Government.

The Fake Zebra of Ukraine

From Russia Today

Police in Ukraine’s Crimean Peninsula have seized a white horse that had been painted with zebra stripes. The equine was a tourist attraction, but its owners have been charged with animal cruelty.

Last year Moscow police resorted to painting horses like Zebras to promote Zebra Crossings.

Just as painting black and white stripes on a horse does not make it a Zebra liberal use of the word ‘Sustainable development’ in government planning documents does not make it sustainable if you define it to mean something else.

National Planning Policy Framework Forensics #26 Transport Policy Objectives

The comparable sections of current policy here are PPG13 (one of the oldest PPGs but revised slightly in Jan 2011), as well as some sections of PPS4 on transport and parking (EC8 and EC18) as well as references in paras 15 and 51 of PPS3.

There has been no overarching statement of transport policy by the new government.  Indeed there has been no statement since 1998 (the Integrated Transport White Paper).

Overall Purpose of Policy

Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability objectives. The Government recognises that different policies and measures will be required in different communities. There is a need to balance the transport system in favour of sustainable modes and give people a real choice about how they travel. However, where these modes are less practical it is recognised that the private car will continue to form an important mode in order to maintain those communities.Where practical, encouragement should be given to solutions which minimise CO2 emissions by reducing the number and length of journeys and to solutions which promote sustainable modes and sustainable technology. to extend choice in transport and secure mobility in a way that supports sustainable development, [through] an integrated transport policy….Land use planning has a key role in delivering the Governments integrated transport strategy. By shaping the pattern of development and influencing the location, scale, density, design and mix of land uses, planning can help to reduce the need to travel, reduce the length of journeys and make it safer and easier for people to access jobs, shopping, leisure facilities and services by public transport, walking, and cycling.The car will continue to have an important part to play and for some journeys, particularly in rural areas, it will remain the only real option for travel.
  •  The NPPF is a more positive statement of sustainable transport than might have been expected.  The key missing element is that the integration between modes of transport and between transport and land use planning.  This is critical.
  • It is not just an issue of different communities but different people in communities.  For example public transport is essential for many elderly people in rural areas.
  • ‘Encouragement should be given to solutions’ wolly and toothless.  Will be used at public inquires to argue that policy is not requiring of sustainable transport.
  • I would suggest as a result this section is reworded as follows.

Transport policies have an important role to play in facilitating sustainable development. The Government recognises that different policies and measures will be required in different communities. There is a need to balance the transport system in favour of sustainable modes and give people a real choice about how they travel. However, where  and when these modes are less practical it is recognised that the private car will continue to form an important mode.

Where practical plans and schemes should minimise CO2 emissions by reducing the number and length of journeys, as well as promote sustainable modes and sustainable technology.

Sustainable transport planning will require an integration of land use and transport planning at all levels, as well as careful integration between different transport modes.

Objectives  of Policy

the objectives of transport policy are to:

  • facilitate economic growth by taking a positive approach to planning for development; and
  • minimise carbon emissions and promote accessibility through planning for the location and mix of development.


The objectives of this guidance are to integrate planning and transport at the national, regional, strategic and local level to:1. promote more sustainable transport choices for both people and for moving freight2. promote accessibility to jobs, shopping, leisure facilities and services by public transport, walking and cycling and3. reduce the need to travel, especially by car

These objectives are deeply worrying.

  • The first is not a transport specific objective at all and could easily be read as sustainable transport=all growth and development which would be a nonsense.
  • The wording could also be read as promoting accessibility by car if emissions are minimised, there are many other impacts of the car, such as congestion, noise, pollution and severance etc.
  • The objectives mention location and mix, but not scale, does planning now no longer have a role to play in controlling density in relation to sustainable transport modes?
  • The phrase ‘reduce the need to travel, especially by the private car’ was a cornerstone of policy and should be retained.
I would therefore suggest that the objectives be reworded as follows:

the objective is by integrating land use and transport planning, to achieve sustainable growth,  to minimise the negative impacts of transport such as CO2 emissions, congestion and noise, and to ensure that development is accessible whilst reducing unnecessary travel, especially by car.

As the current PPG is lengthy it is not productive to carry out a blow by blow and para by para contrast between the PPG and the NPPF.  Rather in the following post I will look at specific topics of transport policy and contrast the overall approach.