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 The old fashioned approach that saw transport planning end at the site entrance was, one hoped, almost superseded.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.’
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:
- 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.
- 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
- 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.
- 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.