National Planning Policy Framework

Written evidence from the CTC, the national cyclists’ organisation

Introduction

1. CTC, the national cyclists’ organisation, was founded in 1878. CTC has 70,000 members and supporters, provides a range of information and legal services to cyclists, organises cycling events, and represents the interests of cyclists and cycling on issues of public policy.

2. The results of planning policy – the location of housing, employment and services – has a critical impact on mobility. Just 2% of trips in the UK are made by bicycle, compared to 10% in Germany, 18% in Denmark or 27% in the Netherlands. Behind much of these differences lie social, cultural and legal differences. However, in large parts this stems from the layout of towns and cities enabling the bicycle to become a mainstream and important form of transport. Average trip distances in Britain by all modes are 7% longer than in the Netherlands (11.7km compared to 10.9km).

3. We are greatly concerned at the professed push to relax planning, ostensibly in the interests of economic growth. Such an approach may or may not result in accelerated investment and development in the short term. However, in the longer-term it will simply condemn us to continued problems associated with the current approach: over-reliance on private motorised transport. The Cabinet Office Strategy Unit has found that the costs of poor transport decisions – principally motorised transport in urban areas - are between £38-49 billion per year. [1]

Presumption in favour of development

4. It is duplicitous to claim that the current framework is seriously impeding development. This appears to be a convenient position adopted in the midst of the financial downturn in order to excuse an otherwise unacceptable dilution of planning standards.

5. Planning policy in the Netherlands has a stronger emphasis than our own on locating developments where they will promote relatively high usage of sustainable and healthy transport modes, with no evidence that this is economically harmful – indeed their economy is in a stronger state than ours. By contrast, the planning free-for-alls seen in recent years in Spain and the Irish Republic have hardly helped them avoid serious economic collapses – indeed it can be argued that unrestrained development may have contributed to the Irish economy’s problems.

Impact on carbon emissions from unconstrained development

6. The wording of the presumption in favour of "sustainable development" makes it very difficult for local authorities to reject planning applications on the grounds of increased greenhouse gas emissions. Conversely there appears to be no means by which Government can measure that the cumulative carbon impacts of planning decisions, either at the local or national level. That makes it impossible either for local communities to hold their local authorities to account for the climate impact of local planning policies and decisions, or for national Government to monitor whether the planning system as a whole is contributing to the reductions in emissions required by the Climate Change Act. In practice, we very much doubt that it would do so – indeed if anything it is likely to lead to an overall increase in transport-related greenhouse gas emissions.

Impact on transport

7. The Government’s current Planning Policy Guidance 13 on transport contains an unequivocal statement of the need to restrain traffic growth and reduce the need to travel. The proposed new NPPF modifies any commitment in this direction with extensive exceptions.

8. Examples of how previous sound principles on the need to shift to sustainable modes are undermined (and where the document would benefit from their removal) are outlined below. We suggest that the sections highlighted in bold should be eliminated from the draft.

"82. …The transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel. However, the Government recognises that different policies and measures will be required in different circumstances and opportunities to maximise sustainable transport solutions will vary from urban to rural areas."

9. In this, the opening paragraph of the section on transport, a potentially powerful statement in favour of sustainable transport is undermined by the second sentence, which appears to give considerable opportunities to developers to plead special circumstances. Given the presumption in favour of development, the ability of local authorities to resist such any proposal is likely to be even more limited.

"83. Where practical, encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion. The planning system should therefore support a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport."

10. In this paragraph an already modest statement of ‘encouragement’ is further weakened to be appropriate only in ‘practical’ (and unspecified) locations. This permits developers to excuse themselves of any obligation to avoid carbon intensive developments (e.g. out of town office or retail developments) using the entirely circular argument that it is neither ‘practical’, to reduce greenhouse gas emissions, nor ‘reasonable’ to facilitate the use of sustainable transport modes, given the unsustainable location they have chosen for their proposed development.

Insufficient detail and guidance to local authorities on standards

11. It is unclear from where local authorities will now receive the ability to apply robust planning guidance on a range of detailed matters. For matters such as cycling – currently a very marginal transport mode for most parts of the UK – this is critical to enable future changes in modal shift to be built into the physical environment.

12. We are also concerned that the "duty to co-operate" does not include a requirement to co-operate with neighbouring authorities on the consistent setting of car parking standards which help reduce reliance on private motorised transport and which instead encourage the use of sustainable transport modes. There is also a need to provide advice on the levels of cycle parking to be provided at different types of development in different types of location.

13. If left to developers provision for cycling would simply not be provided except in locations cycling is already a mainstream transport activity. Therefore areas with historically low levels of cycling (or where developers perceive this to be the case) minimal provision will condemn future users to narrower transport choices.

Recommendations

14. To remedy the above deficiencies, we urge the Committee to recommend:

· The adoption of policies of rejecting planning systems which will (or are likely to) lead to lead to increased carbon emissions with transport compared with the scenario without the development;

· The incorporation of a mechanism for assessing the cumulative climate impact of planning decisions within a local authority area, and for the country as a whole;

· Clarification that the duty to co-operate includes co-operation on the setting of parking standards aimed at discouraging unsustainably high levels of private motorised transport, and the promotion of alternatives;

· The deletion of the ‘caveat’ words highlighted in paragraphs 9 and 10 above;

September 2011