Call 111…For Better Integration of Transport & Land Use Planning of New Developments.

111. It’s the number we call when we need urgent medical help. It’s also the paragraph within the National Planning Policy Framework (NPPF) which, if overhauled to better meet national transport policy aims, could help to better integrate transport and land use planning, and decarbonise the transport impacts of new development.

Currently, paragraph 111 states “Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe”. Paragraph 110 states that it should be ensured that “any significant impacts from the development on the transport network (in terms of capacity and congestion), or on highway safety, can be cost effectively mitigated to an acceptable degree”.

This clear focus around capacity and congestion (and, to a degree, safety, though this is much more difficult to define and assess) sets the framework for how developers and local authorities assess their proposed development at both planning application and Local Plan stages. Even the wording of the NPPF is car centric, with use of the word “highways” rather than “transport” grounds.

As long as the inability to mitigate the capacity, congestion or highway safety impacts to an acceptable degree remains the only grounds for refusal on transport grounds, that is the only aspect of transport planning for new development that will be given adequate consideration as part of the planning process, especially in the current economic climate and the particular need for efficiency in all areas of work. If we are to meet our decarbonization targets within transport, urgent action, and hence an overhaul of paragraphs 110 and 111, are needed now to reframe the focus of the transport element of land use planning.

Within the current planning framework we have:

• Sites coming forward as applications (either Local Plan allocations or windfall sites)
• Sites which are allocated in adopted Local Plans but not currently coming forward
• Future Local Plans

An overhaul of paragraphs 110 and 111 would quickly provide a new focus for any planning applications coming forwards in the short term and bring transport decarbonization to the forefront of planning decisions.

In many adopted Local Plans, strategic growth is identified in peripheral or out of centre locations. In the absence of new planning policy, to gain the greatest benefits from limited resources, there is the opportunity for local authorities, developers and other stakeholders e.g. National Highways, bus operators, future mobility providers etc. to work together post Local Plan adoption to identify the multi-modal solutions needed to best ensure that sustainable transport is a genuine option at strategic sites and a ‘highways mitigation first’ outcome borne out of the ‘predict and provide’ approach does not persist.

Multi-modal requirements could be centred around Government’s awaited accessibility standards or a locally derived measure (such as those included as part of the Leeds City Council Core Strategy).

Looking forward to future Local Plans and 5-year reviews, as part of an emerging Local Plan, local authorities tend to invite sites from developers through the call for sites process, rather than informing consultees and developers of where the most preferential sites are from a transport perspective.

Undertaking a district based transport study to inform where the most preferential locations for development might be (based upon locally derived criteria for transport) and to invite development in those areas, would provide a more proactive and transparent approach to aiming, in the first instance, to locate development in areas which reduce the carbon (and later energy) burden from transport. Locally derived criteria may include proximity to local services; proximity to public and active transport; opportunities to densify development to increase the viability of public transport; access to, but not necessarily ownership of, electric vehicles etc.

In addition, the district-wide transport strategy is often ignored in the Local Plan Transport Assessment despite advice in the Planning Practice Guidance[1] suggesting that the assessment “is likely to be scenario based and in terms of projections look at a range of potential outcomes given a number of assumptions, for example, a movement in the proportion of people using different forms of transport consistent with best practice”.

A greater appreciation of the wider district transport strategy and how this may impact transport choices in the plan period is therefore needed as part of the Local Plan Transport Assessment, alongside a virtuous circle of this strategy then positively impacting the sustainability of the Local Plan sites.

Planning is hard and tough choices have to be made, but as transport planners do we provide adequate evidence to our planning colleagues, early enough in the process, of what sustainable development looks like from a transport perspective? Do we inform them of the best places for transit-oriented development or 15-minute neighbourhoods based on existing (and hence sustainable) services and development?

Do we inform them of the critical mass needed to make a bus service self-sustaining (and hence sustainable) for a strategic site? Do we plan for people by considering the accessibility that might be required according to the planned housing type and ensuring that the required accessibility can be accommodated in a low carbon way, considering advice from institutions such as CIHT[2], RTPI[3] and TCPA[4]?

Can we continue to accept bland Local Plan development management policies which suggest development should “maximise opportunities for active travel” and “ensure frequent and high-quality public transport” with no indication of what this might mean?

If you could call paragraph 111 and ask for help, what would you request………?

[1] https://www.gov.uk/guidance/transport-evidence-bases-in-plan-making-and-decision-taking
[2] CIHT (2019) Better planning, better transport, better places
[3] RTPI (2021) Net zero transport: The role of spatial planning and place-based solutions
[4] TCPA (2021) Garden city standards for the 21st century: Guide 13, sustainable transport