16 March 2018
Peter Blair, Head of Transport Planning (North) at WYG, gave an introduction to the panel discussions at the Northern Powerhouse Conference hosted by the New Statesman in Leeds on 27 February 2018 (Pictured above). Impassioned speeches by Rt. Hon. Lord Michael Heseltine and Lord John Prescott had set the tone for an event rich in ideas and optimistic for the success of the Northern Powerhouse.
In his talk, Peter Blair referenced the draft Strategic Transport Plan by Transport for the North, and the National Planning Policy Framework and its awaited revision, as key enablers that will help pave the way to delivering the Northern Powerhouse. Peter emphasised that whilst transport infrastructure and the digital future may be the foundations of the Northern Powerhouse, the building bricks will be the multitude of housing, office, leisure, health and education developments which will needed to deliver the forecast 850k new jobs and a transformational economic entity of international importance. Northern Planning Authorities will have to find a way to work together and factor the wider Northern Powerhouse objectives into the Planning balance.
Revised National Planning Policy Framework
A few days later, on 5th March, the Prime Minister launched the draft revised National Planning Policy Framework (NPPF). Here, Peter shares his analysis of the draft revised NPPF from a Transport Planning perspective.
The main emphases of the Consultation Draft text of the Revised National Planning Policy Framework (issued March 5th) are to create a larger pipeline of housing supply and increased pressure to ensure delivery.
In relation to Transportation aspects, the changes are more subtle.
The current NPPF paragraph 34 states that “plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised” (emphasis added). The Consultation Draft, paragraph 104 states that “significant development should be focused on locations which are or can be made sustainable through limiting the need to travel and offering a genuine choice of transport modes.” Clearly the Consultation Draft promotes a less onerous approach and should give greater flexibility in identifying suitable sites.
The current NPPF, paragraph 32 states that decisions should take account of whether improvements can be undertaken within the transport network that cost effectively limit the significant impacts of the development; then noting that “development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.”
Despite the passage of 6 years from the publication of the NPPF, no definition of “severe” has emerged. The Consultation Draft does not take the opportunity to define “severe” either.
The Consultation Draft takes that last sentence of the current NPPF paragraph 32, makes subtle changes which could have significant implications and separates it out to its own discrete paragraph (109): “Development should only be prevented or refused on highways grounds if the residual cumulative impacts on the road network or road safety would be severe.”
The changes are that:
• Current NPPF paragraph 32 relates to “transport grounds”, a far wider consideration than the Consultation Draft which limits the test to “highways grounds”.
• Current NPPF paragraph 32 relates the severity threshold to “residual cumulative impact of development” which is a wide planning balance consideration. In contrast, the Consultation Draft relates the severity threshold to the “residual cumulative impacts on the road network or road safety” (emphasis added).
Within the context of the severity test, the Consultation Draft continues the trend of the last 15 years away from the importance of highway capacity analyses. Paragraph 110 prioritises pedestrians, cyclists, providing for people with reduced mobility, safety, security, creating attractive places, allowing for the efficient delivery of goods and access by service and emergency vehicles and the accommodating of charging for plug-in vehicles. Nowhere does it mention highway capacity. Paragraph 111 does require assessment of movement impacts, but places that after the need for a Travel Plan.
Whilst the Consultation Draft text of the Revised NPPF, in terms of Transportation, looks somewhat like a rearrangement of much the same words currently set out in paragraphs 32 to 36 of the NPPF, there is a subtle shift in emphasis which may or may not have been intended. Some of these issues may only ever be explored in Appeal situations under cross examination. It will be interesting to see whether the draft text survives or gets amended through the consultation process.