Memorandum by the Planning Officers Society
WHITE PAPER ON INTEGRATED TRANSPORT POLICY
1. The Planning Officers Society has membership
drawn from the Chief Officers of local planning authorities in
England and Wales.
2. The Planning Officers Society made representations
to government in response to the consultation document and greatly
welcomes the extensive recognition given in the White Paper to
the measures advocated by the Society. The policies contained
within the White Paper represent a sea-change in national policy.
3. In welcoming the government's policy to bring
to bear a wide range of policies and techniques to achieve an
integrated whole, the society recognises that its expertise lies
in the contribution which the planning system can make to this
process and thus its following comments are limited to that area.
4. For the reason that the White Paper represents
a substantial redirection of public policy, much work remains
to be done to apply the new policy direction in practice. The
Planning Officers Society stands ready to assist in this process.
5. The Planning Officers Society presented the
view that previously too great a reliance had been placed on the
planning system alone to deliver fundamental changes in society's
attitudes towards transport. It called for the planning system
to be supported by a redirection of the full range of government
powers and policies in a co-ordinated fashion. The Society welcomes
and supports the extent to which this is proposed in the White
6. In two instances, the Society wishes that
the government had gone further in its initiatives, one for example
in moving from a system of taxation to system of charging as a
way of funding the road network at a national level. The other
in extending local authorities proposed powers to levy charges
for non-residential parking to include out-of-town shopping centres.
Both of these are potentially significant tools to encourage landowners
and occupants to reconsider the use of sites and developments
which do not assist the achievement of integrated sustainable
development,s and also in encouraging the adoption of green travel
7. The Commission for Integrated Transport is
welcomed as a forum for resolving the difficulties which might
stand in the way of some of the hard decisions which remain. It
needs to be briefed to advise on the practicality and timescales
of taking some of these hard decisions. It should provide a continuing
public voice for integrated transport, keeping matters on the
political agenda and not just be a back-room think tank.
8. The relationship to decision making by other
bodies which influence transport was not sufficiently spelt out
in the White Paper itself and further work needs to be pursued.
Much decision making in the transport field is made by private
companies and mechanisms need to be developed to secure their
co-operation with the initiatives to be taken by public bodies.
9. The Planning Officers Society accepts that
the planning system of itself cannot solve the problems of many
decades of misguided transport policies, but it has some concerns
that the Society's message has been taken too far in that within
the White Paper itself there now appears to be an insufficient
explanation of the mechanics of integration of transport with
planning and land use. The Planning Officers Society does not
wish to claim an ascendancy for planning, but it is the relationship
of transport with planning, which now needs to be expounded. Planning
is not marginal to decisions being made now about transport changes.
It is central to decisions being made now about land use changes,
and can make an immediate impact upon securing the objectives
of the White Paper even in advance of further legislation.
10. As is to be expected, the White Paper's
strengths lie in setting a direction and establishing principles.
Attention now needs to be given to means of implementation, from
Regional Planning Guidance right down to Development Control.
Delivery is as important as sentiment, and there now needs to
be considerable work done. Much of the responsibility appears
to fall in the local authority basket, but in many ways, the institutional
framework is lacking. There is no such thing as a single "Local
Transport Authority" and authorities at differing tiers have
overlapping responsibilities. There is a significant task of co-ordination
to be tackled.
11. Attention now needs to be paid to the level
of transport detail expected to be covered in Regional Planning
Guidance. Great store is set by such guidance in the White Paper.
The legitimacy and content of regional transport strategies was
not spelt out, and development work on this issue needs to be
pursued if the current reviews of Regional Planning Guidance are
to address this issue effectively. The new PPG11 will be important
in setting out clear guidance. The capacity of regional organisations
to undertake this work needs to be understood.
12. Local Transport Plans should be a high priority
issue to be examined. The Planning Officers Society welcomes the
concept of local transport plans, including a transport strategy
to reflect the wider context of society's needs such as health,
security, the environment and social exclusion. However, it feels
that the White Paper has given insufficient emphasis to the relationship
between these and other plansin particular Structure Plans,
UDPs and Local Plans, which were hardly mentioned. These relationships
are likely to be particularly critical if local authorities are
going to succeed in delivering the government's objectives. The
Planning Officers Society understands that advice on local transport
plans, and a revision to PPG12 giving advice on the relationship
between local transport plans and the Development Plan system
is in preparation by the DETR. This advice will need to clarify
the following points:
the primacy of plans prepared at
different times and by different authorities;
the hierarchy of plans and the extent
[and direction] of compliance between them;
the spatial extent of local transport
plans and the responsible authority. It may be assumed that they
would be prepared by local highway authorities correlating to
their geographical area, but there could be advantages, particularly
in metropolitan areas or other agglomerations for jointly-prepared
plans, and in some cases jointly prepared plans engaging parts
of several local authority areas. These could build upon inter
authority partnerships and joint working established already between
counties and districts and across borders;
the relationship between the provisions
of the Road Traffic Reduction Act in setting targets, especially
related to developing environmental indicators and the awaited
government sustainability indicators, and what might be included
in Local Transport Plans. Our assumption is that the Local Transport
Plans will incorporate the expectations of the Road Traffic Reduction
Act and this will doubtless be clarified in government guidance.
13. There needs to be a realistic expectation
of the content of Local Transport Plans, especially in detailing
proposals relating to land use/transportation policies in Local
Plans and their ongoing reviews. LTPs will need to reflect changes
in both regional planning guidance and PPGs including the expected
revised PPGs 3, 11 and 12. The preparation of LTPs [which will
involve transport and planning expertise] will consume considerable
staff resources if they are to be effective, and the government
needs to resource this adequately.
14. Clarification is needed about Local Transport
Plans becoming statutory "in due course". Statutory
status has both positives and negatives. The negative aspects
comprise potential bureaucratic delays in allowing for formal
objections by interested parties and possibly inquiries into objections.
Potential benefits could lie in the concept of requiring decisions
by other transport agencies and authorities to comply with the
plan. In moving towards a statutory concept, the benefits need
to be maximised and the disadvantages minimised.
15. The Planning Officers Society supports the
emphasis given in the White Paper on accessibility to jobs, leisure
and services by foot, bicycle and public transport, and the proposal
that Development Plans should give better protection to those
sites and routes which would be critical in developing infrastructure
to widen transport choices. However, in some cases, it is unclear
how the new policies will feed into the day-to-day Development
Control process, and guidance will be needed to ensure that this
happens. Urgent publication of a revised PPG13 is sought, together
with appropriate revisions to other PPGs.
16. Planning policy changesas distinct
from day to day development control decisions, have a relatively
long lead time. There is therefore a need to get to grips with
what planning needs to do sooner rather than later and because
the current situation with the creation and review/updating of
development [and particularly local because there are more of
them] plans is mixed there will be a percentage that are at crucial
stage now if there is to be a significant shift in policy direction
or, more realistically, emphasis and detail. Examples are the
Northamptonshire Structure Plan [draft stage] and the Warwickshire
Structure Plan [deposit draft this Autumn].
17. Car parking strategies to reduce excess
provision will be no more easily achieved as a result of the White
Paper. There remains great difficulty in securing a level playing
field on parking charges across the regional level. The role of
the regional organisations in establishing a level playing field
is crucial. The timescales and mechanisms for Private Non-Residential
Parking charges and road user charging need to be defined swiftly
and there needs to be clarification of the arrangements for the
local use of revenue raised, with parliamentary time given to
the necessary changes in legislation. There is a surprising acceptance
of and commitment to the principles of integrated transport which
will easily be lost if the necessary legislation is delayed. Furthermore,
it is regretted that the opportunity of getting to grips with
parking charges/taxation of spaces at out-of-centre sites, in
order to redevelop surplus parking spaces, has been missed.
18. On the other hand, it might be wrong to
assume that the welfare of town centres depended on accessibility
by car. Mention can be made of surveys showing over 60 per cent
arriving by busalthough the spending power of this group
vis-a-vis that of car owners may be another matter.
19. The legislation for new forms of charging
would be permissive, so money to improve public transport was
not assured. Moreover, there appears to be no penalty for those
authorities who did not implement the new emphasis. There needs
to be greater incentives for local authorities to adopt and carry
through the government's new policies.
Integrated Land Use and Transport Topic Group
24 September 1998