Reform of National Planning Policy Framework - Implications for Transport Planning

The government has today announced its consultation on proposed amendments to the NPPF, designed to encourage a ‘vision-led’ approach to transport planning.

The NPPF reiterates that transport issues should be considered from the earliest stage of plan-making and development proposals, to ensure that impacts are recognised and addressed.

?So, what’s the problem with the current approach? According to the government: “At present, planning for travel too often follows a simplistic ‘predict and provide’ pattern, with insufficient regard for the quality of places being created or whether the transport infrastructure which is planned is fully justified. Challenging the default assumption of automatic traffic growth, where places are designed for a ‘worst case’ peak hour scenario, can drive better outcomes for residents and the environment. It means working with residents, local planning authorities and developers to set a vision for how we want places to be and designing the transport and behavioural interventions to help us achieve this vision. This approach is known as ‘vision-led’ transport planning and, unlike the traditional ‘predict and provide’ approach, it focuses on the outcomes desired, and planning for achieving them”.

?To support this approach, amendments to two key paragraphs are proposed, summarised below (for a side by side comparison - see here).

However, the proposed NPPF reforms are unlikely to materially change the approach unless new guidance is released to clarify what the DfT expect. The need for reform of the transport assessment (TA) guidance is an issue that planning specialist Dr Colin Black recently unpacked.

A vision led approach was feasible within the previous TA guidelines which were withdrawn by the previous government over a decade ago. Technically, in the absence of clarification about what is meant by vision-led, any scheme that does not cater for all future predicted demand for traffic can be (and is) argued not be ‘predict and provide’ and is therefore ‘vision-led’.

?Without clarity on DfT expectations for a vision-led approach the proposed revisions to the NPPF will be ineffectual and have little of the desired impact. So, the key to the NPPF amendments from a transport planning perspective is the need for DfT to commit to provide new guidance to clarify how a vision led approach should be developed and validated.

The government has stated that “To support the implementation of this updated policy, we will publish updated guidance alongside the policy coming into effect”. Developing clear guidelines will take considerably longer to agree and is fraught with challenge for the DfT. To date, only Oxfordshire County Council has adopted TA guidelines consistent with a vision-led approach, based on the TRICS ‘decide and provide’ guidance. A TA Working Group led by Hampshire County Council has set out its recommendations for TA reform to the DfT, and the University of the West of England has published its suggestions for a ‘triple-access’ approach.

All have laudable ambitions, but the new guidelines will need to carefully consider how best to demonstrate that the transport planning strategy proposed for a new development is able to deliver the ‘place’ outcomes desired, and the response required if the agreed strategy fails to meet its objectives.

Mayer Brown have specialised in development planning since 1988 and recall previous attempts to grapple with the same issues over 16 years ago. We will be consulting with DfT to provide practical and pragmatic experience of what works. There is an eagerness from our clients to rise to the challenge of increasing much-need housing and great places to live. The challenge for the DfT will be to create guidance that helps expedite this rather than slow the process down with greater ambiguity or more complexity.

We will continue to keep our clients updated as the planning reforms progress. Do get in contact to discuss your development proposals and, of course, feel free to provide any thoughts in the chat. ??