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This briefing has yet to be completed, and is not yet in a logical order
please feel free to make comments and recommendations for inclusion.

Planning Sanity Briefing on Transport

Transport is one of the primany issues in development campaigns. First there is the obvious new road constructions, but also within this heading comes all those developments that are subject to the special planning procedure known as Transport and Works Orders, which are not approved by local planners but effectively Government manderins, although technically by the relevant Minister. Also we have Airports, which are often very controversial developments. Outside of these actual development areas, we have issues that affect most if not all developments, for instance Green Transport Plans, car parks and access issues. Then finally, though not strictly a planning issue, but is often indirectly connected we have rights of way, this might involve the closure of a footpath to enable a development to take place, or perhaps a diversion. You will see therefore that the topic of transport is far reaching and important to everyone that is concerned about inappropriate development.

Planning Sanity have split this topic into its various headings for ease of reference, the main Transport Forum sets out the topic areas and specialist link indexes, you should refer to this as your main reference tool (please feel free to make suggestions, or send us links and briefings to improve the site). You will also find a selection of draft letters to planning authorities and the Secretary of State, please sendus copies of letters that have used in order that others may benefit from knowing what does and does not hold sway, and to give them sound ideas based on past experiences of others.

Planning Sanity does not offer set out to dictate what is or is not inappropriate development, our sole purpose is to guide local communities through the planning maze, therefore you, or your community must first determine whether the proposal is likely to adversely affect your community, or indeed, you may even want to support a development proposal, or put forward within the local plan process, a development that you consider will benefit your community, in the context of transport, this might mean a bypass, or some other similar proposal. Often local communities can avoid the most destructive elements of a development proposal by suggesting alternative less harmful routes, or proposals. It is the role of Planning Sanity within our own very limited resources to help as best we can, with unbiased, practical guidance.

A useful start to understanding the processes involved in the assessment of development projects and transport is the paper by Nicola Kane for the Transport Planning Society A Guide to the Assessment of Development Proposals and How Transport Issues are Subject to Legal Regulation from Planning Through to Implementation. As this briefing paper sets out a lot of the basics in plain English, including the inter-relationship between policy documents, I shall therefore refer you to her briefing rather than re-invent the wheel. Except that where she refers to the DETR, it has to be kept in mind that the Department of Transport (DfT) has been seporated from other planning areas, which are now the primary responsibility of the Deputy Prime Ministers Office (ODPM), with other environmental issues coming within the remit of Department Environment, Food and Rural Affairs (DEFRA). Which is effectively a decentralisation of the departments that she praises in her opening sentiments as being centralised.

Nearly all developments will have some transport issue involved, simple housing developments will have concerns on access and public transport, commercial developments will have addition concerns on car parking and heavy vehicle movements at unsocial hours, whilst other types of developments will be transport infrastructure, such as bypasses, motorway service areas or even extentions to airports. Into the equation will come topics such as congestion, air pollution, danger spots, where accidents infrequently occure. We shall thherefore keep this briefing to the basics, while the other specialist briefings of Airports, TWA (transport and Works Orders) which includes roads, Rights of Way will deal in more detail with those topics. In addition you will find topic headings such as Public Inquiries, EIA (Environmental Impact Assessment) invaluable. There are other topics that often go hand in hand with developments such as roads and airports, for instance CPO (Compulsory Purchase Orders), therefore always check other headings for advise on those special topic headings. Whereever a specific link is important, then we incorporate that link into the briefing, these may not always show up in the Word or PDF versions, when time permits this will be rectified.

The first start of any transport issue must be PPG13 - Transport - PPG=Planning Policy Guidance Note - There are 25 of these on a range of topics and are the Governments main planning policy guidance documents, which in turn are supplemented by Department Circulars, which are usual shown by the prefix 'Cir', then the number and year, unfortunately not all circulars are online, though the more more recent ones are, however they can be purchased from the Stationary Office, or most book shops. A full list of PPGs and Circulars (with links) can be found on our Legal Forum.

If it is a Transport and Works Order then you will also need to look at Transport and Works (applications and Objections Procedure) (England and Wales) Rules 2000, and the Transport and Works (Inquiries Procedure) Rules 1992. Or where it is a non transport and works Order development and is to be determined by an inquiry then the relevant inquiry procedure rules, these are listed on our Public Inquiry Forum, where it is not to go to a public inquiry then look to our main Planning Briefing or our FAQ (Frequently Asked Questions). The FAQ which will be updated as often as possible is the best starting point for a question of a general nature.

In any event you should have a printed standard letter for general circulation, as well as online. Planning Sanity can help with free WEB space if needed i.e. http://www.planningsanity.co.uk/..............html, where the dots are replaced with your campaign name, you then simply send us the relevant pages, and/or info and we put your campaign online, of course you can also get online with your own WEB site for a reasonable fee to the many companies that now offer such services. There are also a few organisations that will help groups get computer access and WEB space such as GreenNet or see the briefing for GreenNet by Paul Mobbs, or Seeds for Change which offers training and resources for campaign groups.

PPG13 sets out the basic ground rules that planners must take into account when looking at all transport issues connected to developments. PPG13 was updated in March 2001, it is this edition that we refer to in this and other transport briefings. Much of the general transport policy of the Government was set out in the White Paper "A new Deal for Transport: Better for Everyone" published in July 1998, PPG13 is based upon that policy statement. For instance the chart in Annex 'D' of PPG13 sets out the recommended parking capacities for various developments. It is a fact that transport issues give developers the greatest headaches, and it should always be the first port of call. examine the project proposals, then look at PPG13 to see if the national guidelines are exceeded. Then turn to the Regional Planning Policy for our region (unfortunately some regions have yet to have their regional policy documents approved). And finally against both the Local Plan and Structure Plan policies (Note: in County areas there are both a local and structure plan, whilst in unitary and metropolitan areas there is a single Unitary Development Plan). Establishing the transport plan for your area is very important when assessing the potential impact, as well as determining whether a proposal is in accordance with the plan, policy infringments are genuine and positive grounds for refusal of an application. There may also be other local policies in the shape of 'Local Transport Plans', Supplementary Planning Policy and Green Transport Plans. The scheme if it is large may well also have specific site related 'Master Plans'.

Armed with a clear understanding of the relevant policies on transport, applying them to a scheme can be quite simple, even where there is a comprehensive transport assessment. In a briefing of this nature that is intended to over the whole of the UK it is impossible to set out every way that policies might apply to every type of development, but as a simple example: A footbal stadium with a seating capacity of 10,000 should have a 'maximum' of 667 car parking spaces (plus staff spaces). A significant difference either side of this calculation would allow an argument against the development, insufficient spaces would lead to the argument that it would lead to on street parking, thereby having an adverse effect on local residents who would have to bare a considerably greater burden than other sections of the community. Whilst over provision would lead to the argument that there is a greater effect on the natural environment than the project requires, by effectively having a greater land take than is needed. Perhaps this is over simplistic, but it does illustrate that in most circumstances areguments can be found to fit all aspects of a development.

Issues such as access should be given considerable weight in any argument, for instance will the view of the access road be restricted by local features such as bends, high hedges, existing onstreet parking. Will a driver exiting the access be able to see all pedestrians on paths that cut across the entrance, this is often problematic for smaller developments with restricted access, in which a driver has to effectively drive onto that part of the path that crosses over the access, due to a fence, making it impossible to see young children, who tend not to have the same degree of causion, than they do when stepping off the kerb of a main road. The problem becomes acute if there is a primary school within the locality, and where it is reasonable to expect large numbers of children to be passing the entrance on journeys to and from school.

What if any provision within the development has been made for mobility, which is now a requirement. Often sufficient detail is given on access into the building, and car parking, but not for access too and from the site. Is it likely that regular disabled users are likely to be travelling to the development, and if so what are the local problems that they will face, will for instance there be a public transport facility that caters for the disabled, such as buses that lower to allow wheel chair access, is the proposed development at the top of a hill, or other obstacle. Or indeed, how far for both the disabled, and the healthy is public transport from the proposed development. A basic requirement is that developments should be served by a range of transport including, pedestrians, cyclists, public transport and the car. This has to be looked at in the context of the specific development scheme. A small 3 house development would clearly require far less provision than say a supermarket. On appropriate sites there should be good access, including walkways that are well lite, cycle paths with storage facilities.

In site specific transport plans developers will always play down the number of car users, they will do modul splits, setting out that ex number of people will walk - cycle and travel by public transport, check to see if these figures are realistic. What criteria does the developer use to base his figures on. In an urban area that is traditionally subject to congestion such as parts of London and where people are accustomed to using public transport the numbers of bus users will be considerably higher than a rural area with little or no traditional use of public transport, use your own local knowledge to support any contradiction of the figures, and remember that decisions made by the local planning authority will mean that the committee members also live in the local community and will know what you are talking about if you say that the residents of blah rarely use public transport, and that in 19..... a local bus was taken out of service/had a reduced service due to lack of use. Or that the local bus service is only viable due to subsidies by the local authority. make full use of this local knowledge that is often not known by developers, both to strenghen your case and as a gentle reminder to local councillors that it might not be like the rosy picture painted by a developer who's only real concern is his profit and loss account.

When looking at potential developments it is important that local community groups strive to have included within local and structure plans transport policies that will ensure that they have the best advantage in later planning disputes. Once a plan policy is in place then it is difficult to dislodge it, and therefore it is always better to have a mind to the future and play an active part in local plan adoption processes. Therefore think ahead never leaves things until it is too late, a good policy in a local plan may be all that is needed to prevent a development, but a por policy may be the best friend of the developer, therefore overlook the plan process at your peril.

The big divider of many communities is the need for by-passes, with one section convinced that a new bypass will fulfill all its traffic needs, diverting traffic away from local streets. And in the short term this does happen, however, it is a fact that within 5 years most (but not all) road problems return as the by-pass it self becomes congested and drivers look for alternative routes. Albeit there are ways in which this can be prevented such as ensuring that previous through routes are subjected to complex re-routing, traffic calming, and physically terminating the through route by the use barriers. Those arguing against by-passes norrmally base their objection on a mixture of localised congestion caused by the by-pass and the loss of green open spaces. Whilst both arguments will play the air quality argument, and of course both sides are right in respect of poor air quality caused by vehicles, we will look at that inmore detail below. The answer then to the question of the rights or wrongs of the by-pass are not simple, we therefore leave that question for the determination of the local communities affected, it being for the local community to decide what is adverse and what is not, and for Planning Sanity to advise on the appropriate course within the planning process.

Much though can be done to improve local transport needs by first improving local public transport, and in the long term by reducing the need to travel. As well as looking at non-car based personal transport, for instance the provision of better cyclist facilities, not simply cycle tracks, but also secure storage and changing facilities for cyclists. A communter/shopper travelling into town by cycling being able to have a secure and lockable storage space for the cycle, with an adjacent changing room, particularly during the winter months. safe routes to school and other facilities used by the young and elderly, well lit, patrolled by wardens, and/or police, as well as being devoid of obstacles, and features that can be used as hiding places for the criminal faternity. These sort of facilities and well thought out planning of routes can make a significant difference to local traffic volumes, especially if linked to incentives and penalties, of the stick and carrot variety. A school that has restricted parking, or parking limited to those who have to travel a distance by car or bus, including the revenue raising ability of charged parking, that can then be used to fund other forms of transport. With the long term aim of reducing the need to travel, localised shopping precincts, education and employment opportunities, will not only lead to reduced congestion by there implementation, but will also lead to change in the perception that every journey must be by car.

The true scenario of the lorry travelling from Manchester to London laden with biscuits, whilst travelling in the opposite direction is a lorry laden with biscuits (often very similar biscuits), is senseless. As is the present pratice of most of the Superstores having regional distribution centres that often require lorries to pass retail outlets to drive to these centres. Whilst back in the 50s and 60s before Beeching axed the railways, distribution worked in the main by regional and national distribution to railheads, which then used a fleet of lorries to distribute locally, and many of the older generation will remember British Rails Scammel 3 wheeled lorries that undertook the bulk of this work. The lorry would thus only be used for a fraction of the journey, and then only very locally. In our argument therefore good transport management is about reducing the need to travel, reducing the road journey of goods, and the encouragement of alternative forms of travel to the car. These are normally viewed solely as environmental issues, but they are equally, or even more important, for the planning process, and the setting of planning policies for the long term benefit of future generations.

Much is made of park and ride schemes, however in our view the majority of schemes become uneconomic and therefore do not justify the loss of greenfield sites. They further encourage greater use of the car, rather than reduce the use, as people who might otherwise undertake a complete journey by public transport, instead use the car for the majority of the journey, and public transport only for congested parts. The number of spaces required to make any significant difference are rarely achieved, and if they are they are usually so large that the impact on the environment, and loss of greenfields is significantly greater than local conditions permit. However, when used through good planning, and for specific purposes they can be useful tools in helping to beat congestion. Sporting events that use commercial premises with large car parks for park and ride for major fixtures can be benetial. At least one town uses boats for park and sail for shoppers on a Saturday and during the busy Christmas period. These are targetted, rather than the general 'commuter' type park and ride that is uneconomic. It is therefore about identifying a need and catering for that need, rather than taking the approach of far too may planners that assume that by simply providing a park and ride facility they will cure all the local traffic problems of proposed developments.

Similar comments can be made in relation to Green Transport Schemes that far too often are put forward by developers as the big reason why their development will not cause the levels of car use that will in all reality happen. A good scheme can and does have benefits in terms of traffic reduction, these schemes are though usually generated by specific employers, rather than what is the norm that is proposed by developers, who in the majority of cases have little or no control over future occupiers of the sites they develop. The basic scheme is sound, workers are encouraged to use often sponsored public transport, or car sharing schemes, and if the scheme is implemented by commited established employers do and can have a positive effect. But a developer, albeit they can enter into 106 agreements that include transport schemes, have no interest past the end of the development, and most certainly have little inteest in ensuring that a scheme that might hinder the sale of the finished premises. But the schemes persist, therefore they have to be countered, the trick that is used is in the modul split, the developer will claim very high levels of public transport use, or numbers of those sharing vehicles. There are a number of resources on the main Transport Forum that sets out these schemes, the results of studies and so forth.

When looking at proposals, and the figures that developers put forward as justification, such as numbers of likely users, and their likely mode of transport. A useful start for research to counter the arguments is the National Statistics Transport Database. For instance the statistic show us that the average households have the following use of a car - No Car 27% - One Car 45% - Two or More Cars 28%. The following table shows the Journeys per person per year: by main mode and journey purpose, 1997-1999, for Great Britain, the figures are percentages:-

What we are putting across here is that there is a vast amount of resources available, make the most of them, and do not accept figures at face value that are put forward by so called experts employed by developers, after all "he who pays the piper - names the tune". There are ways and means of at least checking whether the information supplied is within the national, or regional average.

A good source of information can be found on USENET (news groups) such as england.transport, which enables questions to be put to those with an interest in the specific topic, although some times the answers can be disappointing, and on some news groups quite insulting, but it costs nothing to ask the question, so long as you ignore those who are more intent on displaying their own self importance rather than being helpful, but the end result can be fruitful, or at the very least point you in the right direction.

Present Government planning policy has its routes in the 1998 Transport White Paper "A new Deal for Transport: Better for Everyone". This has a large number of offspring, all of which are listed (with links) in the reference section of the Transport Forum. However a good explanation of the various documents is set out in the Transport Planning Society briefing paper PPGs and Transport Planning - Do they come together, I would therefore again refer you to that briefing rather than repeating them here. This document also deals with the various PPGs, in as far as they relate to transport, so again please refer to that document for a more detailed overview of the various PPGs, althouh in relation to some PPGs the report is already out of date, for instance PPG8 (Telecommunications) has been updated, and PPG25 (Flooding) has now been published. Although it must be stressed that Planning Sanity does not necessarily agree with any conclusions or sentiments set out in such external briefing papers.

In relationship to mineral extraction sites and transport it is important to look at MPGs (Mineral Planning Guidance) particularly MPG2 - Applications, permissions and conditions. For instance it is a requirement that LPAs should consult with the Secretary of State where a mineral works is likely to affect trunk roads, aqnd to consult Highway Authorities where classified roads are affected. Which always give the opportunity for the decision to be taken away from local planners and put to a local inquiry, as well as opportunities for lobbying other agencies to oppose developments on transport grounds.

The control of traffic through the planning process can be achived in several ways, first by filtering out those developments that in transport terms are totally unsuitably sited in relation to a range of travel options, and which would add to overal car use, thereby creating poor local air quality. Planning conditions, which ensure that access, and facilities are included within developments approved that prevent the worst traffic problems, improve access, and generally ensure that development proposals do meet transport planning policies. Section 106 agreements can take forward proposals that could not be insisted upon as planning conditions, but where it would be inappropriate to grant a permission unless specific criteria is undertaken. Conditions are legal requirments that must be undertaken as part of the grant of permission, but cannot be attached unless they are connected to the development are fair and reasonable, and relate to land in the control of the developer. Thus the insistence on a wide flange for an access could not be set as a condition if it meant cutting across another land owners property, therefore if the development would be considered inappropriate without the condition being applied, it should be dismissed. Similarly with Section 106 Orders, but to a lesser degree, these are effectively contracts that the developer enters into with the planners in order to ensure a development is approved. Thus with our flanged entrance the permission could be approved even though the land is not in the control of the developer, but subject to the terms of the S106 agreement, which most likely would be the addition of a condition that no part of the development is to be started until after land that is subject to the S106 order is secured. Which could be by a private deal between the landowner and the developer, or by compulsory purchase. If the land is not secured then the pemission would effectively cease at the end of the time period set out in the permission, normally 5 years.

Where a development requires an Environmental Impact Assessment (EIA) then Traffic Impact Assessments (TIA) will form an integral part of the process, however other developments that are not EIA developments will require TIAs, and Local Travel Plans (LTP). In the DETR document 'Accumulating Environmental Impacts it makes it clear that when assessing effects it is the most adverse assessment that should be taken into account, and that accumulations of a range of resources is the way that adverse effects should be measured. Thus an area that is generally set aside for commercial developments would need to be assessed not on the individual development proposal, but the potential adverse effect of transport of all likely, or proposed developments on the wider site, and the wider road network.

Far too often local and Central Government seem to think that the easy way out of the transport problems that they are faced with is to fund public transport initiatives, without any thought to the potential harm that those individual development proposals might bring, in terms of local wildlife loss, effect on local residents quality of life, and potentially in places increased congestion. An illustration of this is the Leigh Guided Busway in Greater Manchester, this scheme which Planning Sanity demonstrated on behalf of local residents at the local inquiry would see a grand saving on its 7.5mile lengh in bus journey times of just two minutes, but will destroy a renaturalised wildlife corridor, that is used extensively by equestrians, cyclists, walkers and nature lovers, at a cost of £32million. Yet the fact is there are at least two alternatives, possibly three including reconnecting Leigh to the rail network, which incidentally is the largest town in the NorthWest without a rail connection, for about half of the cost of the proposed Busway. The view that seemed to be taken by the authorities is that any public transport initative must be good, and that they cannot understand why environmentalist were opposed to the scheme, they fail to be able to grasp that good planning is about balancing all the benefits against the disadvantages, and that even the best intended schemes can have adverse effects that need to be taken into account.

Paragraph 2.7 of the Transport White Paper states "Road Traffic is a major contributer to air pollution. Up to 24,000 vulnerable people are estimated to die prematurely each year, and similar numbers are admitted to hospital, because of exposure to air pollution, much of which is due to road traffic." Air pollution is therefore a major factor in any planning project that entails significant vehicle movements. The worst areas for airbourne polution is adjacent to major roads. large car parks, avenues that attract visitors. Even medium sized housing projects can tip the level of pollutants over the top of acceptable levels. Concerns on air quality as with all other forms of potential health hazards caused by development proposals is a material planning consideration, more important though is the fear or perception of an adverse health effect that residents might suffer from. These concerns and fear do not have to be scientifically proven, providing the residents genuinely hold the fear, and what resident would not be so concerned when even the Government attribute such a large number of deaths and hospital admissions to air pollution caused by traffic.

Like air polluton noise is a major factor in issues relating to planning and traffic, and can arguably be the biggest problem for those living close to developments that have a high turn over of vehicles, from the constant hum on major roads, to the starting of cars and lorries at un-sociable hours on car parks, as well as he beeping of the reversing of commecial vehicles at distribution centres. Noise related pollution is both a Statutory Nuisance (Word Doc) and is a health concern that is a material planning consideraton.

TO BE CONTINUED