The recent Chief Planner’s letter, issued in early January, includes a number of announcements. The main one is the consultation period, open until the 2 March, 2023, concerning proposed amendments to the National Planning Policy Framework (NPPF).
Subsequently, there have been numerous articles, posts and viewpoints on LinkedIn and other social media outlets concerning the proposed amendments to the NPPF and the proposed changes to housing delivery targets, as well as articles in major national tabloid newspapers. Rightly so, as the proposed amendments are likely to result in a major change to the current UK planning system with consequential impacts on where and how much housing can be delivered.
However, there are two other announcements in the Chief Planner’s letter, which are equally important considerations to be aware of from a transport planning perspective for future development schemes. Glanville’s new technical director, Tony Jones, reviews their implications here.
ACTIVE TRAVEL ENGLAND (ATE)
Firstly, from 1 June 2023, Active Travel England (ATE), will become a statutory consultee outside London (unless otherwise agreed). As such, Local Planning Authorities (LPAs) will need to consult with them on planning applications meeting the following thresholds:
- 150 residential units (dwellings);
- 7,500m² commercial area; or
- Site having an area of 5 hectares or more.
The aim of ATE is to make walking, cycling and wheeling the natural choice for everyday trips. And that by 2030, 50% of trips in towns and cities are by walking, cycling or wheeling.
Glanville considers that ATE will shortly become an important stakeholder for Local Planning Authorities and developers to engage with proactively when considering potential land allocations and / or planning applications including:
- The provision of pre-application advice;
- Negotiations during ‘live’ planning applications;
- Input and feedback, regards the proposed active travel strategy to be considered for development sites, seeking allocations through the TCPA (Town and Country Planning Association) Regulation 18 & 19 processes; and
- The making of the local plans.
Glanville understands further details on how ATE will approach its remit will be provided in March this year; and we await this news with interest. Glanville hopes that ATE’s approach will be to show pragmatism and flexibility when considering development proposals. Taking into account its holistic impact and benefits, as well as urban and rural location when seeking to achieve its modal share target. Furthermore, Glanville also considers ATE should be flexible in its interpretation of Local Transport Note 1/20 ‘Cycle Infrastructure Design’ considering local site constraints and existing cycle provision.
The policy paper ‘Strategic road network and the delivery of sustainable development’ was updated on 23 December 2022. This document is the policy of the Secretary of State relating to the Strategic Road Network (SRN). It sets out how National Highways (NH) will engage with the development industry, public bodies and communities to assist the delivery of sustainable development. In particular, the relationship between development and junctions with the SRN.
The policy paper advises new developments should facilitate a reduction in the need to travel by private car. Also, new developments should be focused on locations which are, or can be made sustainable. That’s to say, it expects strategic policy-making authorities and community groups responsible for preparing local and neighbourhood plans, to only promote development at locations that are, or can be made sustainable and where opportunities exist to maximise walking, wheeling, cycling, public transport and shared travel.
Given Glanville’s experience working on proposals that include negotiations with NH, there is an important point to highlight:
The policy paper advises moving away from transport planning based on predicting future demand that traditionally considers the impact of development schemes on highway network capacity and potential mitigation known as, ‘predict and provide’ towards more vision-led approaches that considers ways to promote and monitor travel by sustainable transport modes and avoid highway capacity improvements / interventions. This approach is known as ‘vision and validate’, ‘decide and provide’ or ‘monitor and manage’.
NH’s policy paper also advises, the presumption is against new connections onto the SRN. It clearly sets out the onus is on development schemes proposing new infrastructure, to firstly show that all reasonable options to deliver modal shift have been exhausted. First, developers must aim to promote walking, wheeling, cycling, public transport and shared travel, to assist in reducing car dependency and seek development in areas of high accessibility by sustainable transport modes. Or areas that can be made more accessible, before considering options for new connections to the SRN.
We anticipate this will need support from Travel Plans and Active Travel / Public Transport Strategies that have robust monitoring, intervention and implementation of additional measures, if the sustainable transport strategy does not achieve its targets. A Travel Plan Co-ordinator will need to manage these documents.
Before applying for planning permission, developers should anticipate that transport consultants will also need to prepare:
Alongside the expected comprehensive Transport Assessment and Travel Plan Documents:
- A Risk Assessment in compliance with GG 104;
- A Walking, Cycling & Horse-Riding Assessment and Review in compliance with GG 142; and
- Preliminary design and Stage 1 Road Safety Audit (see GG 119).
In conclusion, Glanville advises early engagement with the National Highways. This will ensure the above scope of works and further highway standards in the DMRB are appropriately addressed as part of the scope of transport work required for development schemes that have transport impacts on the SRN. Importantly, NH will need to be fully supportive of the proposed sustainable transport strategy and Travel Plan measures. Otherwise, we consider this could lead to NH issuing holding directions or direction to the LPA to refuse the scheme.