Response to Consultation on Draft Planning Advice Note (PAN) 57 by The Scottish Policy Group of The Chartered Institute of Logistics and Transport (UK)

Introduction
This PAN accompanies SPP17 Planning for Transport and provides good practice guidance on implementing the policies and objectives set out in SPP17. The Policy Group welcomes the opportunity to comment on the draft issued on the 24th March, although it was concerned that insufficient time was available to consultees to develop a comprehensive response by the 16th April deadline for SPP17 consultations. It has taken some time to develop our response to PAN 57 and we trust that our views will still be taken into account. Development Plans and Strategies

The Policy Group welcomes the emphasis placed in this guidance on integration and co-operative working as the best way of developing development plans and strategies. In our view, any discussion of the role of transport modelling in this process needs to emphasise the role of accessibility models such as the "Accession" model currently being developed by the Department for Transport for English local authorities to develop and assess their Local Transport Strategies. This is reinforced by the central role that accessibility analysis takes elsewhere in this guidance.

Policy Development
We welcome the emphasis given in this section of the guidance to accessibility analysis. However, we consider that rather than being used as an "alternative or alongside other techniques", it should in fact underpin many policy developments, in particular those related to land-use planning.

We also welcome the move towards the definition of Mode Share Targets (MST) in development plans and the like, which again would benefit from the use of accessibility analysis to underpin their definition. However, it is unclear from this draft and Annex B how accessibility analysis would be used in this manner. We would therefore recommend further work to develop the link between accessibility analysis and in more clearly setting MST's. There is also an opportunity to consider how MST's could best relate to the statutory requirement on local authorities to adopt road traffic reduction targets.

This section also mentions the use of the "no net detriment" concept as a means of setting MST's. However, we would welcome clarification as to how this would be undertaken. If, as suggested, it means no net increase in travel time then the use of accessibility analysis is implied. Perhaps then, a more fundamental definition would be no net loss in accessibility. The term is also often taken to mean something very different by Trunk Road Network Management when considering traffic impacts of development on the trunk road network. Care will be needed to ensure the concept is applied appropriately and consistently. We welcome the requirement on local authorities to prepare Parking Standards Reports and are in broad agreement with the general method suggested to undertake the exercise.

Development Control
The key foci in this guidance are rightly on the preparation of Transport Assessments and Travel Plans. The Policy Group has already commented on the draft guidance for TA's and note that the period for consultation on these guidelines was extended to 30th June 2004. The Policy Group welcomes this extension given the very significant concerns raised by the Policy Group and other agencies in the implementation of the draft guidelines as they stand. With regard to Travel Plans, the Policy Group welcomes the distinction made between plans submitted at outline and detailed stage, recognising also the difficulties faced where no end-user is identified. Of particular interest is the suggestion that a trust fund for additional remedial measures be set up. It may be useful to define alternative funding mechanisms for developers and local authorities to consider. The guidance rightly points out that "procedures should always be specific to the development proposal to which the travel plan relates". In the case of development extensions it will be necessary to further clarify whether this applies to the extension or the development as a whole.

We would suggest that the requirement for MST's in Travel Plans be made explicit in the guidance. This would be consistent with the development of local authority policy and development TA's. MST'S would be underpinned by accessibility analysis and guided by the effectiveness of particular measures as defined in previous research, (see Annex E). This section of guidance also addresses the problems involved in implementing Travel Plans for residential uses. We would suggest that setting MST's for residential developments is practicable where procedures for monitoring and enforcement are clearly identified and agreed between all parties. There are no guidelines for monitoring Travel Plans and, as a result, the quality and usefulness of Travel Plan monitoring reports are variable. We would suggest that consideration be given to the development of Travel Plan Monitoring Guidance for application in Scotland, in a similar vein and linked to the emerging guidance on Transport Assessment technique.