Guide to Transport Assessments in Scotland: Response to Consultation by the Scottish Region of the Institute of Logistics and Transport.

Introduction
The Institute is the professional body for the full range of people who are engaged in logistics and transport. This includes freight and passenger transport operators, central and local government employees, consultants, supply chain management and academics. Some of these would be directly affected by proposals in the Consultation document whilst others would be subject to varying degrees of impact on their working lives. The views on this expressed in this paper are confined to those members of our Policy Group who have contributed.

Background
In the past the Institution of Highways and Transportation (IHT) Guidelines for Traffic Impact Assessment were initially aimed at providing guidance to all those parties involved in preparing and auditing Traffic Impact Assessments. In time these Guidelines were formally adopted by the majority of local authorities, to reflect the authorities own policies. It should therefore be borne in mind that in time the Scottish Guidelines may also be formally adopted, possibly replacing the IHT Guidelines, and as such care is required to ensure these Guidelines are explicit and clear in the guidance they give.

Overview
The main change in attitude to transport assessments recently, has been through the movement away from car based assessments towards multi-modal person trips. This shift is to be commended, however at present there is very little data available for multi-modal trips and these are not always appropriate outside the congested urban areas, where populations are dispersed and therefore the potential for non-car trips are low. Notwithstanding the above, the Institute welcomes the comprehensive approach taken to addressing the needs of all modes of transport. However there is a concern that there is a lack of prescriptive detail when identifying the scale of the assessment to be undertaken. As a result a considerable emphasis will be placed on practitioners to adopt a consistent and sensible approach when applying the guidance. The structure of the document is considered to be appropriate and clearly outlines the Transport Assessment process and the role of those involved. The Institute welcomes the inclusion of Technical Appendices providing additional information. The comparison of Transport and Traffic Impact Assessments is considered particularly useful. While the Institute supports the Scottish Executive in producing such a document it believes that a clear distinction must be made between those organisations responsible for developing policy and those responsible for developing practical guidance for the industry to use.

Part 1: Transport Assessment: Scope and Process
This document brings a degree of consistency between the planning guidelines (e.g. NPPG 17: Transport and Planning on which the Institute provided comments) and the Transport Assessment Process. This is welcomed by the Institute as it clearly sets out the framework for those either producing or receiving Transport Assessments. In general the process outlined builds upon what is currently considered to be good practice. The Institute believes that it is vital that the key stakeholders are involved throughout the process. The introduction of the Transport Assessment Forms (Appendix A) are also welcomed, providing that they are not used as a substitute for full assessments. The Institute does have some concerns over the reference to monitoring Transport Assessments (para 5.6). Recent practice would suggest that Section 75 Agreements provide the only robust mechanism for incorporating monitoring. Any other method may prove to be difficult in practice to enforce.

Scoping of the Transport Assessment is a vital stage in the process. The Institute believes that the guidance given in the document relating to what should be agreed at scoping stage and how to undertake the transport assessment are perhaps too simplistic and subjective. As a consequence many areas within the document remain open to interpretation, which could give rise to protracted discussion at the planning stage or lengthy public inquiries. The Institute would therefore advocate the introduction of clearer thresholds similar to those set out in the IHT Guidelines. The guidance sets out the criteria for Transport Assessment. This is based on good practice and is generally consistent with the NPPG 17 criteria. This consistent approach is welcomed. The Institute welcomes the recognition of freight within the Transport Assessment process. This is often neglected within Transport Assessments, partly through a lack of understanding of the impact. However in many instances the impact of freight traffic can cause greater concern to those directly affected. The role of the respective stakeholders is very clearly identified and it is hoped that this introduces further levels of accountability within the process.

Part 2: Transport Assessment: How to Assess the Site
The Institute welcomes the move away from the previous "predict and provide" approach. The order in which the respective issues should be addressed is a clear recognition of the need to consider the location of the proposed site and its level of accessibility as primary drivers in the assessment process. The reference to four of the five appraisal criteria of accessibility, environment, integration and safety is consistent with the Scottish Executive's transport policy. While the Institute supports these principles there is a concern that in practice very little will be done to address these in a robust manner. There is a general belief, that as the current policy stresses the importance of non-car trips, there is the potential for reduced car usage and therefore lower trip rates. While there is no doubt that non-car trips should be given precedence in a development, care and consideration is needed to ensure that the trip potential for a development is robust and reflective of the proposals. The guidance is not clear on whether or not the IHT Guidelines are to be considered in tandem, as there are areas where the two documents conflict i.e. the IHT guidance states that development impacts should be considered 10/15 years after opening, whereas these guidelines only state 1 year after opening or 15 years for a trunk road. Therefore the Institute believes that the guidance should clearly state the relationship between this document and others, such as the IHT guidelines.

Part 3: The Transport Assessment Toolkit
The Institute is supportive of the inclusion of this part of the document as it provides an ideal checklist for those producing and reviewing Transport Assessments. The guidance on preparing travel plans is welcomed, however it is not always possible to implement such a scheme as part of a development as they are generally unworkable on anything but the largest developments. It would be beneficial if some thresholds could be identified to guide all parties on the size and types of developments that would warrant a travel plan. It is also worth bearing in mind that targets and travel plans are not enforceable unless a Section 75 Agreement or Planning Conditions are in place, which is not always the case. At present there is very little information available to determine how effective travel plans are at reducing car dependency and therefore it is not possible to quantify the influence a travel plan will have on reducing the number of vehicular trips to a development.

Application of the Document
The Institute supports all the principles contained in the document and welcomes the move away from the "predict and provide" approach. However there is a concern that the level of subjectivity is such that the guidelines may be difficult to implement in practice. Furthermore recent concerns of the CBI regarding the lengthy planning process may indeed be exacerbated as practitioners debate the applicability of many of the principles. Given the above the Institute would wish to see more prescriptive guidance introduced to address the fundamental requirements of the Transport Assessment.

It is considered that, given the complexity of some of the issues raised in the guidance, it is important that it is made clear that the document should only be used by those qualified to do so. Furthermore the Institute is concerned over the resource implication, particularly for those smaller local authorities that do not have the level of expertise required to advise on the matters raised within this document.