Yesterday (12 December 2024), the Ministry of Housing, Communities and Local Government (MHCLG) published its updated National Planning Policy Framework (NPPF) for England.
The transport chapter promises a new ‘vision-led’ approach to transport planning. This is intended to replace the “traditional ‘predict and provide’ approach”, in which predictions are made of the motor traffic the development is expected to generate, and roads and junctions are provided accordingly. Unsurprisingly, those roads and junctions fill up with motor traffic, making the predictions entirely self-fulfilling.
So you might be heartened that NPPF calls on those assessing proposed sites or actual development proposals to “ensure that […] sustainable transport modes are prioritised taking account of the vision for the site, the type of development and its location” (para 115).
It also tells those submitting planning applications to “give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and second – so far as possible – to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use” (para 117). This is all good stuff.
Nothing new
I’m afraid though that we’ve been here before. In 1994 – yes, thirty years ago – the Government issued Planning Policy Guidance note PPG13 on transport (not available online). It said that “Development plans should aim to reduce the need to travel, especially by car, by […] fostering forms of development which encourage walking, cycling and public transport use.”
Four years later, the late John Prescott’s Transport White Paper declared that “The days of ‘predict and provide’ are over“, with Governments of all colours echoing this sentiment ever since. Successor documents to PPG13, right up to the current NPPF, have all called for sustainable transport modes to be prioritised, to reduce car-dependence.
Yet, as I noted last week, recent reports from the Royal Town Planning Institute and New Economics Foundation have shown that housing has, if anything, become more car-dependent – in spite of all the fine words of PPG13 and its successors over the years, right up to the current NPPF. And motor traffic on Britain’s roads has doubled since 1980 and increased 10-fold since 1950.
Meanwhile, the new NPPF still makes it really hard for local planning authorities to reject car-dependent developments. It tells them that “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, following mitigation, would be severe, taking into account all reasonable future scenarios” (paragraph 116).
I’ve previously critiqued an earlier version of this paragraph. The small changes to the wording are unlikely to change anything, particularly given that the Department for Transport’s ‘National Road Traffic Projections‘ (see right hand part of the above graph) suggest that motor traffic in England and Wales is set to continue growing in all possible scenarios, by up to 54% by 2060. These projections will still inevitably be used to assess the motor traffic likely to be generated by new developments.
So councils or public inquiry inspectors will still end up concluding that new roads or junctions are necessary to “mitigate” this “impact”. Even where the council would rather the developer came up with something much more sustainable, paragraph 116 will make it almost impossible for them to reject car-dependent developments – particularly since the developer can usually afford to mount an appeal much more easily than the cash-strapped council can afford to resist it.
What’s the ‘vision’?
Yet you might still be wondering, don’t the words “vision-led” add something new?
Well, they could have done – and there’s still a possibility of turning them into something positive.
It would have been fantastic if the Government had defined the ‘vision’ as being a future in which motor traffic is reduced by at least 20% by 2030 – which plenty of evidence suggests is needed to meet the UK’s legally-binding climate targets – and by more than that to meet air quality and other targets in urban areas.
Unfortunately though, the NPPF says nothing of the sort. Instead, it defines “vision-led” as meaning “an approach to transport planning based on setting outcomes for a development based on achieving well-designed, sustainable and popular places, and providing the transport solutions to deliver those outcomes as opposed to predicting future demand to provide capacity (often referred to as ‘predict and provide’).”
So local authorities or developers will be able to propose whatever “outcomes” they want for their development, together with transport solutions to deliver those outcomes. The resulting “visions” will then all be equal in the eyes of a public inquiry inspector tasked with deciding whether a development should be given planning permission. This really doesn’t get us anywhere.
More obstacles
Meanwhile the new NPPF puts two other obstacles in the way of the fine words of paragraphs 115 and 117.
The first is paragraph 110, which starts promisingly: “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. This can help to reduce congestion and emissions, and improve air quality and public health.”
Yet it then ends by saying: “However, opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision-making.” In other words, rural local authorities shouldn’t try too hard to reduce car-dependence.
The second obstacle is paragraph 113, which creates a strong presumption against setting any upper limits on the amount of car parking that should be provided. “Maximum parking standards for residential and non-residential development should only be set where there is a clear and compelling justification that they are necessary for managing the local road network, or for optimising the density of development in city and town centres and other locations that are well served by public transport.”
Meanwhile of course, local planning authorities (LPAs) in rural areas are still going to have to meet their housing targets, which the Government is allocating to them without taking account of the availability of brownfield land or public transport services.
Given this, it won’t be surprising if LPAs continue assuming that their ‘vision’ has to be one in which motor traffic carries on increasing – just not quite as fast as it might have done without their chosen policies.
They will then continue allowing the volume house-builders to build identikit low-density housing all over the country – like the housing in MHCLG’s picture at the top of this article – with plenty of car parking space but without public transport or other key facilities (e.g. schools, healthcare, shops, green open space) within a safe and easy walk or cycle-ride from those homes.
So the residents will still need cars for their day-to-day journeys – and the developers will continue to feel justified in providing plenty of car-parking space. Yet car-parking and ample road widths are exactly what makes it harder to provide green open space, places where children can play, or good walking and cycling facilities. That of course further entrenches car-dependence!
We’ll therefore continue hurtling towards a climate catastrophe, just as we were before the NPPF was published.
Another future is possible!
This isn’t the end of the story though, for several reasons:
- The Government has promised a Planning and Infrastructure Bill in the current Parliament.
- The Department for Transport is developing an Integrated National Transport Strategy (INTS), due to be published next year, which is also expected to be “vision-led”.
- The INTS will need to be in line with the strategy to achieve ‘net zero’ which the Government is legally obliged to publish by 2nd May 2025, after the courts ruled twice that the previous Government’s net zero strategies were legally inadequate.
- Finally, MHCLG is committed to produce new Planning Practice Guidance note on transport, to clarify its ‘vision’. It is also likely to produce National Development Management Policies which will apply in all parts of England, to save local planning authorities duplicating national policy in their Local Plans.
So we need to press the Department for Transport to adopt a transport ‘vision’ that is in line with next Spring’s new net zero strategy, then for MHCLG to reflect this in any further updates to planning policy. The Planning and Infrastructure Bill could be a very timely opportunity to push them on this.
A different vision: ‘Close knit communities’
Meanwhile you can help raise parliamentary awareness of the need for a very different ‘vison’ for future housing. The Low Traffic Future alliance has defined ‘Close knit communities‘ as places where:
- Schools, shops, doctors, dentists etc are close to where people live;
- There are safe and easy ways to reach these and other key destinations by walking, wheeling or cycling and/or by public, shared or community transport; and
- Motor traffic is therefore kept in check, because the alternatives are preferable to driving.
‘Close knit communities’ would:
- Be located close to high-quality public transport, or where this can be easily extended to serve the new development. This helps avoid the need for residents to own cars and for excessive car-parking provision (see below).
- Have road and path networks which are designed to enable safe walking, wheeling and cycling by all – including children and people with disabilities – with key destinations being easily and safely accessible by these modes.
- Be built to high but ‘gentle’ densities, e.g. at least 40-60 dwellings per hectare. Building 4 to 6 storey dwellings allows high-quality homes to be built on less land, with shared garden spaces, while also generating the density of demand for public transport services needed to ensure they are well used, and thus remain financially viable.
- Minimise the space given over to car-parking. This in turn frees up space for walking and cycling and for an attractive public realm, including green open space, benches and places where children can play.
Consultancy Create Streets has shown that this approach can deliver a 60% reduction in the land needed for a given number of homes. For 1.5 million homes, that would be an area the size of the Isle of Wight. It can also significantly increase the number of trips made by walking, cycling and public transport, while reducing car use and car-dependence.
‘Close-knit communities’ would mean cleaner air, safer and less congested streets, safe and ‘neighbourly’ communities where children can play outdoors, and where people could make shared use of cars without needing to own them. They would reduce the costs of living, support local businesses and protect the NHS, while contributing to a net zero future.
Crucially, they would allow the Government’s 1.5 million homes to take up less land, generate less motor traffic and hence fewer objections, in ways that would benefit our health, our wealth and the local and global environment.
Tell your MP we need ‘Close knit communities’
So please tell your MP that this is the kind of housing we need! The more we can build up parliamentary support for these ideas, the greater the chance of getting them adopted when Parliament starts debating the Planning and Infrastructure Bill in the coming months.
We’ve made it easy! We’ve set up a template email, ready to be sent to your MP. But do please add local examples, either of bad or good recent housing in your area, or places where housing should or should not be built. MPs are much more likely to speak up on an issue if they can talk about their local area when doing so.
Finally, please forward any responses you receive, to hello@lowtrafficfuture.org.uk. We look forward to hearing from you!
Roger Geffen