Response to Consultation on Draft Scottish Planning Policy 17 - Planning for Transport by The Scottish Policy Group of The Institute of Logistics and Transport

1. Background.
This will supersede NPPG9 (Motorway Service Areas), NPPG17 (Transport and Planning), SPP17 addendum to NPPG17 (maximum parking standards) and sets out the principles by which planning for transport is to be undertaken.

2. Overview.
Although the continuing development of national policy to guide transport planning is welcome, it would appear that in comparison with the current NPPG17 guidance (including the maximum parking standards addendum) the main aim of this consultative draft is to integrate the guidance with NPPG9, and to provide an update that accounts for recent developments such as the Airport White Paper. The document is comprehensive and we welcome the Executive's intended objective of reducing the need to travel. We would recommend that land-use plans be co-ordinated with Regional and Local Transport Strategies. We also take the view that these proposals should be related to the "Draft Guide to Transport Assessment in Scotland" (observations submitted by ILT on 11th Dec. 2003) and which we feel should be published as soon as possible.

3. Policy Context.
Although this section is fairly comprehensive in setting out the policy context for this emerging policy, it would also seem pertinent at this stage to mention the five key criteria for considering new transport schemes at this stage as defined in the Transport White Paper and Scottish Transport Appraisal Guidance (STAG). Reference to the changing guidance on Transport Assessments is also relevant in the development planning and control context.

4. Major Strategic Projects.
The guidance in this section is structured around providing for transport by mode. However, providing (or indeed not, where appropriate) for travel goes beyond these definitions. There are "major strategic projects" such as urban and inter-urban road user charging regimes, for example, for which the Executive has an opportunity to set national guidance. We welcome the requirement in paragraph 9 that development strategies should include mechanisms (e.g. masterplanning), to secure developer contributions where the need for major infrastructure is anticipated. This will require close working between developers and public sector agencies and should be undertaken to the satisfaction of both the public and private sectors.

Although there are many examples of good practice in this area, there are other examples where poor co-operative working between the two sectors has led to delays. While masterplanning contribution strategy is a good idea it is essential that where a lack of contributions result, this approach should not prejudice or substantially delay developments - there must be a determined fall back position. The process of working up new Development Strategies, Development Plans, and Structure Plans offers the opportunity for enhancing the roles of Transportation staff alongside colleagues from the planning profession if the importance of integrating land-use with transport planning is to materialise in practice.

We would suggest that paragraph 12 should be explicit in the likely types of impact from development strategies that local authorities should examine. In many cases, it is often confined to fairly simple "predict-and-provide" traffic impact methodologies, where broader economic, accessibility, and social equity impacts, for example, are of equal if not greater importance. With reference to paragraph 13, the emphases in planning for rail projects should include planning for national, regional and high speed lines as well as local services and freight lines.

The guidance provided on planning for airports (paragraphs 15-17 inclusive) is narrowly focused on a demand-led response to air travel growth in Scotland. We are concerned that this misses other relevant responses such as investment in high-speed rail, and demand management responses, in particular where growth in air demand is primarily "short-haul" in nature and damaging to the atmospheric environment. The role of air freight and its future development should also be reflected in this guidance. The guidance also fails to mention the need for local authorities to have due regard to third party and environmental impacts of airport development, and hence ensure proper compensation measures are considered.

We welcome the guidance and emphasis given throughout this document to the proper development of walkways and cycle paths linking developments and providing trip makers with a viable, environmentally benign alternative to car-borne travel. Routes need to be safe in the sense of how they interact with roads etc but also in terms of lighting, proximity to habitation and aspect. Well-surfaced, lit and drained pathways combined with a perception of relative security provide reassurance that women, children and other vulnerable people groups can use them safely and enjoyably. More dedicated cycle lanes beyond a line in the road also need to be constructed especially where traffic segregation would have safety implications.

However, if really serious about cycle use, then there should also be a codifying of the provision of enclosed lockers at strategic points in developments to keep bikes and their equipment dry and secure. The Executive should consider developing national minimum cycle parking standards as an extension to the existing maximum car parking standards. These could usefully include consideration of the type of cycle parking appropriate to different land uses, locations, and parking durations. These distinctions are present in some but not all local authority guidelines.

>When planning for seaports guidance should also be issued on the development of shipping routes for passenger as well as freight traffic. There are many opportunities for improving links with Europe through supporting the development of passenger facilities at, for example, Rosyth and Peterhead. At some of Scotland's Ports, investment in passenger travel could assist in the regeneration of areas suffering downturns in more traditional industries such as fishing.

5. Local Development Plans and Transport Projects.
In general we welcome the aims set out in this guidance for Local Development Plans and Transport Projects. These include the reservation of disused transport routes and the designation of development areas as easily accessible by public transport. Consideration should also be given to the prioritisation of road freight over private travel on the road network in the many circumstances where road-to-rail transfers are not viable. This can take the form of goods vehicle priority lanes and charging regimes.

We would advise caution in the case made for short-term car parking in paragraph 30. Short-term parking may in fact not support accessibility in many circumstances where it facilitates high volumes of traffic relative to long-stay parking and consequently works against the availability of road space for other modes. It also only improves accessibility for those who have access to cars. On this point, we would reinforce the need for plans and projects to be subject to comprehensive appraisal against STAG guidelines, including accessibility and social equity audits.

6. Assessing Development Proposals.
We welcome the aspiration for developments to be sited as indicated but are aware that in many cases (e.g. Royal Bank of Scotland at Gogar!), these are overridden by other economic and political considerations. We recommend that guidance be developed to define the prioritisation of transport planning aims within the broader context of other social and economic concerns when considering planning applications. We suggest that in considering shift working issues for certain employment land uses that recognition be given to the contribution that this dispersion of working hours makes to the overall level of demand for parking, although where shift patterns overlap there may be brief "spikes" in demand.

We consider it inappropriate to finalize those parts of this guidance relying on the guidelines for transport assessment, which have also yet to be finalized. There are significant areas of concern in the current draft guidelines for Transport Assessment, which will have been identified by the associated consultation process and to which ILT has also responded (see above). We are also concerned over the apparent complacency in paragraph 41 re: residential parking. There are many opportunities for non/less-car residential development, which respects the needs of pedestrians, defines the residential street as a medium for social interaction and removes the potential blight and safety risks of parked cars.

In paragraph 44 recognition should be given to the growing expertise in the development of Demand-Responsive Transport (DRT) across Scotland. DRT is known to be particularly useful in rural areas for reducing car dependence. Councils should ensure that these and other innovative solutions (e.g. farmers markets) appropriate to rural accessibility issues are addressed before relaxing maximum parking standards.

It is disappointing and in sharp contrast to policies and processes advocated elsewhere in the guidance, that when it comes to management of the Trunk Road network (paragraph 55), the focus of transport planning solutions remains fixed narrowly on achieving "no net detriment" to the flow and safety of traffic on the network and "require the developer to fund major road or junction improvements where the volume of traffic or type of road warrant it". This "predict and provide" approach to trunk road management belongs to a bygone era and is long overdue a proper review against broader STAG and policy objectives, which would consider and define the role to be played by more innovative and contemporary planning approaches such as Travel Plans and accessibility analyses.

7. Conclusions.
The ILT in Scotland welcomes and supports the more positive and pro-active approaches to transport and planning in Scotland advocated by this document. Its main achievement is to integrate NPPG17 with other key policy statements such as the Aviation White Paper and NPPG9. There are other policy areas which impact on this guidance (e.g. NPPG8 Town Centres and retailing) which should also be referred to where appropriate.