The Revised National Planning Policy Framework: What’s changed from a transport perspective?
The 24th July saw the long-awaited publication of the Government’s revised National Planning Policy Framework (NPPF). This is the first revision since it was originally published in 2012. The NPPF is the over-arching planning document for England and Wales and sets out how development plans should be prepared by Local Planning Authorities (i.e. plan-making) and how development proposals should be reviewed (i.e. decision-taking). The public consultation on the draft revisions to the NPPF ran from March to May 2018 and prompted nearly 30,000 responses, and also saw #NPPF trending on Twitter on the day of its release.
The Framework’s improved structure (clear chapters based on topic rather than core planning principles), and focus on delivering housing through high quality design, Garden City principles and clearer planning guidance appear to have been received positively by critics, but will the revised NPPF’s transport planning policies be well-received too?
At first glance, the transport policies contained within the document appear to be a reworking of the previous NPPF text. The guidance for Local Planning Authorities (LPA) to follow if setting local parking standards has remained largely the same as in the previous Framework, with an increased encouragement to set standards for EV (Electric Vehicle) and ULEV (Ultra Low Emission Vehicle) parking facilities in place of simply acknowledging the need to reduce high-emission vehicles.
The revision specifically mentions support for LPAs in setting maximum parking standards (paragraph 106), but only 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 locations well served by public transport. Following criticism from transport and planning groups which considered this to be too discouraging of what is a key method of controlling urban sprawl and car use, the reason for the inclusion has been justified with the following response: ‘The approach to parking standards remains that minimum or maximum standards may be set locally, but with maximum standards requiring particular justification, considering the effect that limits on spaces can have on on-street parking’. The response continues that ‘the text has been amended to recognise that such justification may exist in accessible locations where it is appropriate to optimise densities (in line with the new policies on making effective use of land) …’. Whether or not this will satisfy critics, the NPPF’s tone is clear that the setting of parking standards should be considered thoroughly by local authorities, and should only be used as an opportunity to provide high density development at the expense of parking in certain locations or circumstances.
There is also a notable promotion for ensuring sufficient lorry parking is provided, particularly at new or expanded distribution centres, perhaps recognising the growing importance of these facilities in recent years due to the shift in retail behaviour from high streets to home deliveries.
All developments which generate significant amounts of movement still need to be supported by Transport Assessments, Transport Statements and Travel Plans, however these documents are now mentioned in the same paragraph (paragraph 111), with Travel Plans mentioned first. This subtle change, whether intentional or not, corresponds with the Government’s overall shift in recent times towards prioritising sustainable travel, away from simply assessing road network impacts.
The often-debated lack of clarity on the point at which highways impacts become ‘severe’ enough to require refusal of a development (paragraph 109) will continue due its inclusion in the revised NPPF, except for a slight rewording to clarify that the ‘severe’ test relates to impacts on highway capacity only. ‘Unacceptable’ impact on highway safety will be the main other, equally as subjective, reason for refusal on highways grounds. Further advice on this is promised by the Government in future revisions to national planning guidance, but at this time, we expect LPAs will continue to determine whether they believe highways impact to be unacceptable on a site-by-site basis.
Overall, the implications of the revised NPPF to transport planning are therefore expected to be minimal in the short term, and will require the production of new local plans by LPAs to establish how the changes have been received. In the meantime the planning process, including appeals, will likely provide clarity on a case by case basis as LPA’s are required to take on the new NPPF from the date of publication, regardless of the status of their existing plans. Local Plans will be examined based on the policies in the previous Framework where those plans are submitted on or before 24th January 2019.
A copy of the revised NPPF report is available online from here. If you would like further information on how transport policy may impact on your development, please get in touch with Peter May on firstname.lastname@example.org.