Housing Development and Highways - will we ever break the link?

HOUSEBUILDING AND TRANSPORT have a close and sometimes difficult relationship, and one that often brings professional challenges for transport planners as they seek to square the interests of developer clients, local planning authorities, affected communities and wider objectives for the provision of sufficient new homes of the right kinds, and in the right locations, whilst meeting sustainability objectives. Regrettably the ground rules upon which good decisions should be made are far from clear, and thus argument and frustration seem inevitable under the current framework. Meanwhile the politics of housing and planning continue to be a hot topic – no more so than when elections are looming, both local and national. And then the question obviously arises of whether a change of Government, as seems likely, will make any difference.

For context, the current Conservative government has a target to create 300,000 new homes per year. However, the average achieved over the last 10 years has been just 60% of that number. During that period commercial housebuilders brought forward 81% of all new homes, housing associations 18%, with local authorities responsible for just 1%.

Twenty years ago, the Treasury under the then chancellor, Gordon Brown, commissioned Kate Barker to undertake the “most detailed housing review in 50 years” and with the hope it would provide the blueprint for future governments to tackle the affordability and supply challenge. The 2004 Barker report set out some challenging numbers on required housing supply and concluded that much greater public investment would be required to drive forward delivery, as the supply from housing associations has never replaced the one-time significant local authority ‘council housing’ provision, which at its peak accounted for 40% of output. Over the last two decades successive governments have, however, been unable to inject the public funds identified as necessary to deliver on house volume aspirations, as numerous economic shockwaves have caused politicians to reprioritise funding, and plans for new homes developments are often resisted at the local level.

Politicians are not short on promises in this area. At the last Labour Party Conference leader Sir Keir Starmer announced that his Party would “get Britain building again”, promising a next generation of new towns without tearing up the green-belt, though only limited details have been emerging in the run up to the impending election.

So far, all Labour has committed to is:

• A housing recovery plan; a blitz of planning reform to quickly boost housebuilding to buy and rent and deliver the biggest boost to affordable housing in a generation, enhancing local voice on ‘how’ housing is built with communities confident that plans will be delivered.

• A next generation of ‘new towns’; new communities with beautiful homes, green spaces, reliable transport links and bustling high streets.

• A package of devolution to Mayors, with stronger powers over planning and control over housing investment.

• A ‘Planning passport’ for urban brownfield development; with a fast-track approval and delivery of high-density housing on urban brownfield sites.

• Giving younger people the first chance at homes in new housing developments with a government-backed mortgage guarantee scheme.

Meanwhile, for the Conservative Government, Levelling Up, Housing and Communities Secretary Michael Gove has been playing tunes on planning policy and council decision-making processes and times, whilst promoting the notion of ‘building beautiful’. In this he has reflected ideas from thinktank Policy Exchange and campaign group Create Streets, which wants “beautiful and popular” new neighbourhoods guided by design criteria, with a proposed “School of Place”, which, as Gove put it, would enable architects and planners “to go out and build beautiful, sustainable places in which people and communities can thrive”.

Gove issued revisions to the National Planning Policy Framework (NPPF) on 20th December 2023 just before Christmas, as part of changes made by the Levelling-up and Regeneration Act reforms, including changes to planning policy consultation, which were intended to facilitate these aspirations, along with other changes. The NPPF sets out the planning policies for England and how these are expected to be applied. It has been revised several times since it was first published in March 2012 and since its creation, the NPPF has contained a chapter on sustainable transport.

The NPPF replaced the old Planning Policy Guidance 13, which some would argue was a more focussed look at how transport should be dealt with in the planning system. Some of the wording introduced by the 2012 NPPF was intended to address criticisms of PPG13, but it also assisted the promotion of major highway investment, such as the statement that “Local authorities should identify and protect, where there is robust evidence, sites and routes which could be critical in developing infrastructure to widen transport choice”. This requirement has subsequently been expanded in the NPPF to emphasise the need also to identify routes that would be critical to “realise opportunities for large scale development”.

PPG13 was intended to integrate planning and transport at the national, regional, strategic and local level and to promote more sustainable transport choices, both for carrying people and for moving freight. The NPPF theoretically does the same job, and means transport is a material consideration when taking decisions on planning applications, especially where the Local Plan is absent, silent or relevant policies are out of date. The NPPF, together with the Planning Practice Guidance (PPG), set out what the Government expects of local authorities.

In the NPPF (2023) Chapter 9, Promoting Sustainable Transport, it says that transport issues should be considered from the earliest stages of plan-making and development proposals and includes the following paragraph (retained from the previous version) that is positive, as stated below:

The NPPF, however, clearly states (para 115) 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 would be severe”. Herein lies enormous ambiguity and inconsistency of application as there is substantial confusion, politically, legally, and in policy terms as to what constitutes ‘severe’. We currently have a bizarre situation where promoters of major highway investment projects can uphold that their impact on the local road network is not ‘severe’, regardless of often highly convincing evidence to suggest otherwise; whilst the promotors of development that has only marginal impact on the highway network frequently find themselves locked into lengthy challenges from the highway authorities, preventing planning approval until such time that a scheme has been agreed to increase the highway capacity sufficiently.

Whilst the NPPF provides for the ability for progressive strategies to deliver on sustainable transport, it does not go far enough to restrict schemes that lack ambition or even undermine the ability to deliver on laudable policy aspirations. The opportunity to overtly reflect the need for carbon reduction, and the imperative to address the Climate Change impacts of development, has not been grasped, and the current wording of paragraph 115 seems to marginalise it in that only ‘severe’ impacts are accepted as criteria for refusal of planning permission. The change not made is something that various transport professional bodies, including the CIHT, have repeatedly called for, most recently in its ‘Fixing a failing planning and transport system’ document at the end of 2022.

It is apparent that further progress on planning policy is much needed to address ambiguity and ensure that sustainable transport is at the heart of the planning system.

Transport considerations have consistently been a major constraint to the pace and styles at which new housing can be brought forward. With every housing allocation, the capacity of the local road network becomes an emotive and politically charged issue which constrains the ability and willingness to expedite plans. The political preference is commonly to condition housing on the requirement for new highway investment from central government to increase traffic capacity. This requires the planning authority to work with the local (and strategic) highway authorities to invest in the development of design options, consultation, and to develop a business case to compete for funding from the Department of Transport (DfT).

This whole process takes considerable time over many years and substantial lobbying and political case-making to be successful. With cash-strapped local authorities the first hurdle is often to align local and strategic highway authorities to successfully secure funding to cover just the substantial consultancy costs required to apply for DfT funding. If funds are successfully secured, they do not cover the total costs, only a percentage. The difference in funding needs to be found by the local authority, which tends to draw on a combination of income from Council Tax and from developer contributions. The risk of local highway project cost increases and over-run lies squarely with the local authority, and this means they regularly need to find additional funds not originally envisaged, further inhibiting progress.

The process of securing the funding for highway investment commonly considered necessary to support housing is expensive, time-consuming and riddled with risks for the local authority. Crucially, this process also demands substantial funding and resource. There is a significant opportunity cost to this approach, as any money spent on securing new highway infrastructure is not available for other investments that could be used to improve the viability and accessibility of housing sites.

The high cost of major highway investment can meanwhile seriously inhibit the viability of housing development and limit funds for community facilities, sustainable transport and placemaking. For example, it is not uncommon to see a developer required to spend very sizeable sums to significantly upgrade the forward visibility for a 30mph route to provide compliance with DMRB standards, when common sense would suggest that such expenditure would not be a priority if the funding could be better allocated to assist the delivery of the vision for placemaking and sustainable access. A bigger part of the problem is the Transport Assessment process connected to housing development which is used to model and predict the scale of highway investment needed.

The 2007 Transport Assessment Guidelines were officially withdrawn in 2014 but are still widely used in the absence of a suitable replacement. Officially, the age of ‘Predict and Provide’ relating to transport provision has long since passed, ushering in an era variously described as ‘Vision and Validate’ as advocated by Professor Peter Jones, and ‘Decide and Provide’ by Professor Glenn Lyons, who is also advocating a change to Triple Access Planning. Both professors have explained their concepts in detail in recent issues of LTT and their papers can be read here https://tapas.network/41/jones.php[1] and https://tapas.network/52/lyons.php[2]

However, whilst the new conceptual thinking is out there - and a popular topic of discussion in transport planning circles - the way in which national and local highway authorities still require the Transport Assessment approach to be applied frequently contradicts the new broader ideas in the intent of policy. Whilst it is theoretically entirely possible to determine a lower car-use strategy for a development site in accordance with the 2007 Transport Assessment guidance, what tends more often to happen is that predicted requirements for highway and parking infrastructure are based on historical data for similar types of site.

This approach was codified in the creation of the TRICS database 35 years ago, which remains the ‘go to’ tool for transport planning consultants. Over 250 consultants in the UK and Ireland (plus about 20 in Australia) are listed as members of TRICS, licensed to use the database, along with around 100 local authorities, and 6 universities. TRICS was originally developed to provide traffic data for Traffic Impact Assessments, which was the ‘traffic only’ assessment that preceded the Transport Assessment guidelines. Following the introduction of the 2007 TA guidelines, TRICS increased the quantum of multi-modal surveys in the database, followed by the introduction of surveys to provide a Standardised Assessment Methodology (SAM) to assist the ability to capture and use travel plan monitoring data, with the intention that travel plans would be developed in alignment with PAS500 published in 2008. Whilst the database now contains multi-modal data on people movement built up over many years, the majority of the data available provides information on vehicles only (which includes 2-wheelers). A substantial proportion of Transport Assessments continue to be undertaken on the basis of evaluating the likely demand for vehicle movements and ensuring that there is capacity on the network sufficient to accommodate this demand. The vehicle demand assumptions tend to be based on what is expected, based on historical data, rather than what could realistically be achieved for a development. Few local authorities challenge transport planning consultants to reduce the traffic demand assumptions. Most highway authorities prefer to err on the side of caution and ensure adequate vehicle capacity is available to accommodate a new development based on historic precedent for traffic generation. It is entirely within the remit of the local authority to require a reduction of traffic anticipated from historical data, based on the successful implementation a sustainable transport strategy, encompassing a travel plan, and embedding travel behaviours to optimise potential for use of active travel and public transport, however, this approach appears to have fallen out of favour over the last decade.

There remains no requirement in policy to demonstrate that a transport strategy minimises traffic demand, only that the transport impact can be accommodated or mitigated. In recognition of the policy gap, in 2021 TRICS produced a ‘Guidance Note on the Practical Implementation of the Decide and Provide Approach’[3] however three years on there is little evidence of highway authorities moving to formally to adopt this approach as a requirement for planning. In the absence of national policy each highway authority would need to separately adopt a requirement setting out how their Transport Assessments should be undertaken, a politically charged and complex challenge likely to lead to differences in policy approach across the UK. That said, differences in policy approaches are already evident across the UK, with devolved authorities (and some metropolitan, unitary, and county authorities) adopting elements of the vision and validate approach.

The key point is that whilst there are some other helpful (if not becoming overly complex and confused) approaches, in the absence of specific policy guidance there remains too much ambiguity in the system to enable principled politicians and/or civil servants to deliver on their place aspirations, in the face of local political or developer ambitions intent on continuing to do things the old way. The Transport Assessment approach is open to, and prone to, abuse leading to sub-optimal outcomes for quality of place (i.e. liveability, health, accessibility) and the environment.

Greater clarity on the Transport Assessment process is desperately needed, as it is too often continuing to be used to bake-in requirements for new highway investment as a prerequisite for planning. Very rarely, do local planning authorities start with the premise of delivering housing allocations with no, or only very minor, requirements for additional highway investment, or with creative and attractive alternative modal choices or design features that reduce the need for travel.

We need more focus on what is going wrong, to determine how best to change things with genuine impact. Decide and Provide, Vision-Led and Vision and Validate are theoretical approaches that are struggling to be implemented convincingly in the current policy environment. More investment in the non-highway elements is desperately required to make the accessibility offer for new developments work effectively. To do this, there will need to be a re-allocation of existing developer contributions and a re-prioritisation of local and regional transport investment to meet the new objectives - both in terms of neighbourhood design and place making, and the pathway to decarbonisation and Net Zero.

Consultants ITP recently attempted to simplify the approaches at a webinar on vision-led planning hosted by the Urban Design Group, but in doing so aptly demonstrated why there is so much confusion.

Rather bizarrely, we can now even find Vision and Validate being used to justify road schemes that are acknowledged to experience traffic congestion from opening. The intention is that the approach is used to decide on a vision for the type of place that will be provided, in terms of inclusive access and local movement patterns, and then to plan a strategy that delivers this. In reality, the Vision and Validate approach is also being used to justify and exacerbate a continued car dependent society, an issue highlighted by the Transport Committee in its review[4] of the draft revised National Policy Statement for National Networks, see paras 40-43.

The challenge remains that there is too much ambiguity in the process, and what it is striving to achieve. This is due largely to the political paranoia of being considered ‘anti-car’, which appears to have created an unwillingness to provide the policy clarification necessary. Consequently, this has created substantial confusion through distortion of the Transport Assessment approach. For example, in the recent £10bn Lower Thames Crossing DCO Examination, National Highways (NH) audaciously claimed that they had indeed adopted a Vision and Validate approach and not a Predict and Provide one for the scheme, as it only catered for a 50% increase in traffic across the River Thames to the east of London. This logic was also used to justify the acceptance of significant traffic congestion at opening, as after all, according to their logic, if they had applied a Predict and Provide approach, then the scheme would have needed to be much bigger to cater for more traffic. The NH vision was in fact for a highways scheme that did not cater for the transport needs of the housing requirements set out in the relevant local plans, nor optimise active travel, nor take the opportunity to promote and optimise public transport as part of an integrated solution. The fact that this contradiction went unquestioned by the Examiners clearly demonstrated the lack of understanding of the objectives of the Vision and Validate approach.

How the new Oxfordshire guidance presents implementation Appendix 1: flow-diagram summarising the implementation process of a ‘Decide and Provide’ approach to transport assessment

Click to see the image enlarged.

Common sense should surely be applied to identify if a vision fails to address critical issues facing society, or when it is impracticable, divisive or creates serious additional problems in provision or resource requirements, but the ambiguity evident in the process is used to mask its inadequacy.

At a local authority level, Oxfordshire has been pioneering in establishing requirements for decide and provide[5] formally adopting[6] the requirements based on the TRICS(2021) guidance in September 2022. The implementation process, as shown in the diagram below, highlights the key requirement for scenario testing. The guidance emphasises the importance of a Decide and Provide ‘way of thinking or mindset’ to do this effectively. Herein lies a key challenge for an industry that remains firmly embedded to a Predict and Provide mindset.

Whilst this local policy clarification for Oxfordshire allows for a more holistic approaches to transport provision, it is operating in a national policy vacuum which creates substantial ambiguity undermining its effectiveness. It is currently too early to determine whether Oxfordshire’s unilateral move has been successful and can be sustained following the rigours of legal scrutiny through the planning system, and political challenges made.

The lack of national policy has meant that devolved authorities, city regions and the larger highway authorities have developed subtly different approaches creating inconsistencies across the country. Indeed, it is likely that most planning authorities believe they now follow the principles to a certain degree, promoting cycling and walking infrastructure and designing the layout of schemes with these modes as the primary user, leaving the car until last. The challenge is in raising expectations and recognition of what is to be the new normal. A lack of appreciation of the constraints of the current system can lock in a perceived indifference of the need for change.

The biggest problem with the Vision and Validate approach is that there is no defined policy approach for arriving at a preferred or good vision, or indeed for determining that a vision is inappropriate or sub-optimal. To prove that a vision is sub-optimal would require the local authority to invest considerable resources in developing a counter- factual scenario, which itself is then likely to be heavily contestable. In theory, low levels of car use are achievable with the right infrastructure, but what is practical and appropriate in a specific location is a value judgement prone to local political and community influence. Another, practical challenge is the ability of the planning authority, to uphold the transport planning requirements over build out periods that often extend way beyond the initial period envisaged. This challenge in further exacerbated in two-tier Councils where the planning authority is reliant on the advice of a separate highway authority. Major development sites across the UK commonly take over 20 years (sometimes closer to 30) to build out. They are being built on the basis of outline planning permissions with master-plans created in a different era, with a different ethos, and different design standards. There tends to be little appetite to take opportunities to adjust the detailed design, as planning authorities rarely offer to reduce cost, say for highway investment, to cover the additional cost of re-design, say to accommodate adherence with LTN1/20 standards.

The Chippenham case study of how new development can be less car dependent, from the recent Create Streets and Sustrans report

The upshot of these challenges is that significant opportunities to create the sort of sustainable transport-based housing desperately required in the UK continue to be stymied by the implied need for major highway investment. In the absence of clarity on transport policy, highway authorities revert to highway-based approaches often accompanied by, so-called, supporting sustainable travel measures, which are really just a bolt-on. A substantive proportion of S106 /Community Infrastructure Levy (CIL) ‘planning gain’ monies are meanwhile siphoned to pay for highway infrastructure investment. Frequently, moreover, the highway needs are over-specified, perpetuating car-dependency and failing to address inclusivity through a range of mobility and accessibility options. Crucially it often means that there is insufficient funding to invest in placemaking /community /liveability issues that provide a far better return on investment than road building and are the cornerstone of local economic regeneration.

This topic was focus of a helpful research study of Chippenham, summarised in a report by Sustrans and Create Streets published earlier this year – “Stepping off the Road to Nowhere”. The Chippenham case study[7] provided a practical and inspirational example of how highway investment could alternatively be spent, whilst improving accessibility in an inclusive manner, and substantially enhancing the quality of place.

The report emphasises what can be achieved by taking a different approach to transport modelling for new development. The authors reiterate that to “make this way of doing development the norm rather than the rare exception, we need to change policy and practice at the level of national government, local authorities and communities. Most importantly we need to change the assumptions and models behind development projects themselves. Fundamental to achieving this will be much greater integration of spatial planning with transport planning at the local level to create a clear plan for how each authority will achieve its placemaking and sustainability vision.”

Use of the Predict and Provide approach to inform the spatial allocation of housing as part of the Local Plan process, embeds assumptions for new highway capacity as part of the local planning strategy. This can then make it more challenging to adopt an alternative approach developed through Vision and Validate, as it runs contrary to the perceived (and approved) wisdom as articulated in the Local Plan. Use of Vision and Validate must therefore be deployed much earlier in the process to avoid it being undermined by policy contradiction. To effectively deliver the benefits of Vision and Validate, a substantial proportion of Local Planning Authorities will need to rebase their Local Plan, taking a different approach to transport modelling. This is a prospect that would create substantial concern from planning authorities, given the significant resources and timescales required for successful adoption of a Local Plan.

The Sustrans and Create Streets report makes pertinent policy recommendations for the Department of Transport (DfT), Active Travel England (ATE), Department for Levelling Up, Housing & Communities (DLUHC), Homes England (HE), and Local Authorities. Importantly, it recognises many of the embedded policies and approaches across government that together undermine the effectiveness of implementing a Vision and Validate approach. For DfT, it recommends:

It might be hoped that every transport consultant advising on development planning would be keen to adopt the contemporary approaches, of Decide and Provide or Vision and Validate. However, the vested interests of the large multidisciplinary consultants that dominate the market in working with the major developers and local authorities are of particular concern. The Predict and Provide approach has been established on the premise of highly complex and very expensive transport models that have become a crucial income stream for the large foreign-owned multidisciplinary l consultancies whose financial focus is dictated by the uncompromising demands of international markets. Predict and Provide also tends to create substantial highway design and delivery projects related to new development that are now a critical part of a long-established business model for the large multidisciplinary consultants, and there can be a reluctance to promote practices which might, or are perceived to disrupt or constrain the pipeline of future such highway work. At the other end of the scale, the plethora of micro-consultancies evident in the industry are frequently predicated on a business model that offers cheap transport statements and basic assessments using TRICS-based data for a predict and provide approach. Embracing Vision and Validate across the industry would require significant re-skilling to provide the quantum of professionals equipped to deliver integrated, inclusive, attractive, and sustainable places. Equally, moving away from Predict and Provide would fundamentally challenge the basis of the Road Investment Strategy (RIS) for England upon which National Highways is reliant to sustain its expenditure of £12m per day[8]. Furthermore, many Local Plans would require rewriting and policies changed, which would create a significant resource burden for Local Authorities. Such obstacles would appear, on face value, to be insurmountable. However, the crucial importance of severing our reliance on Predict and Provide to justify major highway investment has been highlighted by the stance taken by the Labour-led Welsh Assembly[9], which has set conditions for future highway investment which now better align to the ethos of Vision and Validate, in order to better align transport with its policies on sustainability, economic growth and quality of life. It remains to be seen whether the bold steps taken in Wales will be replicated for England by a future Labour government. The General Election campaign lines have been set by the Conservative’s ‘Motorists’ Manifesto’[10] who believe that by polarising the debate into pro and anti-car it will help them win back a few more votes. From a transport planning perspective, it appears to pit those who believe in the need to transfer towards a Vision and Validate approach to address sustainability, social and economic issues – with those who wish to maintain the status quo of the Predict and Provide approach.

Bringing us back to original focus of this article, it is clear that clinging on to historic norms of highway design where it is considered necessary to accommodate predicted traffic demand certainly isn’t helping to expedite much needed less car-dependent housing. Proportionate investment in necessary roads need to be better balanced with investment in integrated transport and placemaking to create the liveable and sustainable places needed for future generations. Might anything change under a new Government? Labour has not yet provided much detail on its plans for transport, nor whether it will commit to create a much-needed national strategy although the Conservative’s popularist ‘Plan for Drivers’ has unfortunately constrained willingness to communicate any hard truths associated with a more rounded view of transport. Labour has committed to improve and green public transport, delivering this by working more closely with devolved governments and local authorities. Where Labour makes commitments to ‘build transport infrastructure’ they are not yet explained in any detail as to whether they are specifically with reference to public transport, what the approach to road building will be, and the full ingredients of the avowed need to create a safe, efficient, integrated, accessible and affordable transport system[11].

Whoever forms the next government, it is clear that decisive action to strengthen the basis of on transport planning as related to new development is needed to convincingly lock in measures to decarbonise the transport system, no more so than in catering for a significant growth in housing provision.

How can we make that vital step? What are your thoughts on the future of housebuilding and the role of transport planning? There is an urgent need to recognise and tackle the issue of practical implementation to move us beyond the theory. Do share your opinions in the discussion and comments section of the version of this contribution on TAPAS https://tapas.network

References and Links

1. https://tapas.network/41/jones.php

2. https://tapas.network/52/lyons.php

3. https://www.trics.org/img/trics%20dp%20guidance_web.pdf

4. https://committees.parliament.uk/publications/41770/documents/206912/default/

5. https://www.oxfordshire.gov.uk/sites/default/files/file/roads-and-transport/ImplementingDecideandProvideTARequirements.pdf

6. https://mycouncil.oxfordshire.gov.uk/documents/s62101/CA_SEP2022R12%20Implementing%20Decide%20and%20Provide_TA%20Requirements.pdf

7. https://www.sustrans.org.uk/media/13413/stepping-off-the-road-to-nowhere.pdf

8. https://nationalhighways.co.uk/media/0k1mwvsp/nh_ar23_interactive.pdf

9. https://www.gov.wales/welsh-government-response-roads-review-html#:~:text=As%20a%20result%2C%20the%20Welsh,demand%20for%20private%20car%20travel.

10. The Motorists’ Manifesto - is it all hype, or could it really change the transport agenda? LTT magazine, LTT877, 4 October 2023, pp. 8-10.

11. https://labourlist.org/2023/10/labour-national-policy-forum-final-document-summary-policy-manifesto-party-conference/

12. National Planning Policy Framework