The Institute welcomes the opportunity to comment on this Planning Guidance. The comments below are focused primarily to aspects of the NPPG dealing with the relationship between transport and planning for economic development.
2. Policy Framework.
The context for land use planning for economic development, the Framework for Economic Development in Scotland is recognised. The Framework's acknowledgement that such development should be undertaken in a sustainable manner is very much welcomed, as is its reinforcement in para 8 of the NPPG where "securing new development in sustainable locations" is identified as one of the 4 objectives of the NPPG.
It is also recognised that many of the issues related to the integration of transport with planning for development, and the meaning of "sustainable" or "accessible" locations are dealt with in NPPG 17 "Transport and Planning", as indicated in para 29. However, NPPG 2 needs to be much clearer that "sustainable locations" means locations that reduce the need to travel, especially by car. Further, paragraphs 30 to 34 give little guidance about how the transport advantages and disadvantages of different types of location should be balanced, and appear so general in nature as to be of little assistance to planners, developers or the public.
A rather more systematic approach to these issues would be helpful. In particular, the distinction between different types of development and their transport needs should be more clearly developed. This applies particularly to the distinction between developments that are large employers - which require good public transport accessibility and developments that generate substantial amounts of freight movements - which require good access to the road network. Within these categories, and particularly for large employment sites, the Institute believes the Executive should consider the adoption of a "sequential approach" similar to that used for retail developments.
It would also be helpful to define standards and indicators of accessibility to public transport networks that can be used to make comparisons between alternative development locations and benchmark against existing development. The discussion of "key sites" in para 33 is a starting point for this, but needs to be substantially reinforced if it is to have any effect. The policies for Transport Development Areas (TDA's) in England and Wales provide a much stronger basis and ILT endorses and commends the guidance on TDA's produced by the Royal Institute of Chartered Surveyors.
It is also important that issues of "micro" accessibility are taken into account in considering the transport choices open to users of the new development. For example the detailed location of bus stops vis-à-vis parking areas, or attractiveness of pedestrian access into the development will at the very least influence the perceptions - and probably the behaviour - of users about relative accessibility.
3. Provision of Transport Infrastructure and Services.
The proposals in the draft NPPG focus almost entirely on locations with existing public transport infrastructure and services. In the right circumstances, and particularly in the context of "key sites"/TDA's the provision of additional infrastructure or services may be appropriate. Clearly this would need to be part of an overall development plan framework, and timing and funding of such improvements coordinated with development.
It is crucial that where new development is predicated on the provision of new or improved transport, there are binding arrangements that will ensure the provision is actually put in place, and that it is of a quality and permanence that make it a real choice for users of the new development over the long term.
The NPPG does not mention a key issue in this respect - the provision of developer contributions towards funding of improved transport provision. Satisfactory frameworks to ensure developer funding of public transport improvements of both a capital and revenue nature are needed. As highlighted in the previous paragraph, funding agreements of this kind require contractual commitments to ensure provision of the improvements at the appropriate time. Any new legislation or guidance arising out of recent research on The Use and Effectiveness of Planning Agreements should take account of these issues.
Travel plans can be a mechanism for identifying the provision that should be made. These should be given much more emphasis in the guidance, not just a mention in the context of decentralised developments (para 31). There should be more onus on developers to demonstrate how real access choice will be provided and to meet appropriate targets for travel by different modes to their development site.
4. Monitoring and Enforcement of Conditions and Agreements.
A key issue is the monitoring and enforcement of the implementation of the standards together with other planning conditions and agreements. This is not referred to in the NPPG and the Institute is very concerned that in general, inadequate resources are available for carrying out these activities. Action by the Scottish Executive in partnership with local authorities is required to address this issue if the transport impact objectives of new developments are to be met. A similar comment has been made in the Institute's response to consultation on Maximum Parking Standards (NPPG 17 addendum).
5. Points of Detail.
Para 52: Dialogue with business should include relevant transport interests.
Para 57: Development Plans should also ensure that sites identified for potential development are provided with adequate accessibility by existing or planned transport systems.
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