Is this the chance to finally deliver new housing served by sustainable transport?

FRESH IN GOVERNMENT, on the 30 July, Angela Rayner, Deputy Prime Minister and Secretary of State for Housing, Communities and Local Government, announced plans to stimulate the delivery of new homes to address a much-documented shortage of housing in the UK. In her letter[1] to local authority Leaders and Chief Executives, she emphasised that the plan is ambitious, radical and not without controversy, but justified this by the urgency to address housing, particularly the need for social and affordable homes. Part of the plan is for the creation of a significant number of new towns and substantial urban extensions. Obviously, the challenges of delivering housing are complex and multi-faceted and transport gets a mention, emphasising a requirement for all developments to be supported by the “infrastructure needed – including transport links”, with an emphasis on going beyond provision just for road traffic.

But after a number of false dawns down this path, we have again to ask, has all the relevant thinking about the relationship of housing development and transport really been done – and is there still the opportunity to get the rules right this time. In her letter Rayner recognises “the role that planning plays in the broader needs of communities”, and transport certainly gets appropriate recognition in the proposals she sets out. Indeed she pledges to introduce changes to:

• take a vision-led approach to transport planning, challenging the now outdated default assumption of automatic traffic growth;

• promote healthy communities, in particular tackling the scourge of childhood obesity.

This announcement sparked an avalanche of messages across the transport planning community, just as the summer holidays kicked in and professionals started to decipher the implications. The emphasis on health is welcomed, albeit a missed opportunity to reinforce the importance of active travel. What is perhaps more impactful, however, was the government’s formal acknowledgement that a default assumption of automatic traffic growth is “outdated”.

To instigate the plethora of changes necessary to stimulate an increased supply of housing, the government meanwhile announced consultation on a detailed set of proposed modifications to the National Planning Policy Framework (NPPF), some of the provisions of which are of fundamental significance to how transport is planned in relation to new development. Readers may recall that in a previous article in the Local Transport Today, edition of 23 April[2] this year, I undertook a detailed analysis of the huge challenges there have been in unlocking housing development that is not car-dependent whilst the disavowed paradigm of predict and provide for road traffic continues in prevailing custom and practice. A central tenet of the article ‘Housing Development and Highways – will we ever break the link?’ (TAPAS, 23 April 2023), was that a major reform of transport planning including new guidance on transport assessment is crucial to delivering the homes in the inclusive, liveable places oft referred to by Ministers.

It is therefore encouraging that central to the proposed NPPF modifications are an emphasis on the need to adopt new guidance on transport assessment, and specifically the need to move away from the embedded predict and provide approach. But let us mute our excitement with a little realism – and maybe a dose of cynicism too. Seasoned transport planning professionals will recall a similar call to action when the last Labour administration under Tony Blair came into government in 1997. Under the stewardship of John Prescott, then Deputy Prime Minister and Secretary of State for Environment, Transport and the Regions, significant reforms of the planning system were brought in from 2001-07, intended to promote sustainable transport and to shift emphasis away from the predict and provide planning that underpinned the discredited Conservative ‘Roads to Prosperity’ programme.

In this period we saw updates to the Planning Policy Guidance 13: Transport, and the introduction of the first Local Transport Plans. It seemed a fantastic time to be a transport planner, as it felt that at long last the profession was being taken seriously. The first decade of the new millennium saw the publication of (Green) Travel Plan Guidance for new developments, a substantial government-sponsored programme of advice and training, PAS500 national standard for Travel Plans, and then the new Transport Assessment Guidance in 2007.

The UK at the time was providing international leadership in this field, though in reality, on the ground, only limited progress was being made in the new housing developments being built. Then the 2008 global recession hit, and two years later a new Conservative-led coalition government was elected in 2010. Many organisations lobbied the new government for reform to the Transport Assessment guidance to make it easier to build housing – the allegations being that the requirements were making it ‘too difficult and expensive’ to bring forward development, and the sustainable transport ‘visions’ were unrealistic, costly and inappropriate, particularly given the still officially predicted rising demand for motoring. Catering for motorists was considered particularly important by the new government. In 2014, the DfT quietly and without fanfare withdrew the 2007 TA guidance.

During the subsequent decade the DfT has said little about transport assessment, largely leaving the local highway authorities to determine their own requirements. The current, but old, DfT guidance[3] provides policy context, but little substance on how transport statements, assessments and travel plans should be developed or enforced, leaving this to the local highway authority to interpret. This has led to a wide range of nuanced, and arguably unsuitable, approaches being adopted with many inconsistencies. Anecdotally, the lack of clear guidance has inhibited ability to agree appropriate access requirements for numerous new housing developments.

So, are we now potentially about to reset transport planning to a similar position as that envisaged 20 years ago.? Early signs are that the new government does not yet fully appreciate the detailed implications and wider ramifications of the seemingly well-informed rhetoric that it has started to use about the need for vision-led transport planning, and the need to embed unambiguous guidance of how to deliver it in the new policy roll out.

Proposed Reform to NPPF

The current 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 - but not exactly how, and what transport and traffic impacts are not acceptable. On the 30 July the government proposed reforms[4] to the NPPF and other changes to the planning system. This was accompanied by a consultation document listing 106 questions, many of which are wide ranging in nature.

The draft revised NPPF is helpfully presented by MCHLG for consultation alongside the existing version.

In relation to transport, according to the government, the problem is that:

“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”[5].

To support this approach, amendments to two key paragraphs in the existing NPPF are proposed, summarised below (MHCLG has also provided a useful side by side comparison[6]). The key changes highlighted are the emphasis on a vision-led approach, and when development should be refused on highways grounds.

The section below is at its core.

The government proposed reforms also state that “To support the implementation of this updated policy, we will publish updated guidance alongside the policy coming into effect”. This could be critical. The consultation closes on the 24 September 2024 and there is an optimism that a new NPPF could be published for the 2025 new year. This would mean that, to be relevant, new guidance on transport assessments would need to be prepared, consulted on, and made available within a very short period of just a few months. This seems extremely optimistic unless the DfT have already got a good draft ready to go.

On their own, I fear the proposed reforms to the NPPF wording are unlikely to materially change the approach towards transport. It is the promised guidance that will hold the power. In my judgement the wording used in the consultation draft is currently still too vague, the use of ‘in all tested scenarios’ (paragraph 113 in the above excerpt) potentially renders it ineffective. After all, there will always be some tested scenario where there would not be a severe effect from the traffic generated by a development.

The guidance will thus need to be clear on how the scenarios are decided - and who decides. Key to effective guidance will be clarity of the policy objective. For example, is the government objective to create housing developments that would not have a severe traffic impact on key tested scenarios? What if the relevant local government objective is to deliver a highway to bypass a particular town, and requires contribution from a housing developer to fund this? Defining the new scenarios that should be tested will require considered thinking about the potential unintended consequences, or routes that may be legally deployed to circum-navigate the intended or implicit, revised policy objectives.

Vision led approach

Adopting a vision-led approach to transport planning will not in itself significantly change the status quo. Looking at the recent publicity from most of the transport consultants, it would seem, to an innocent observer, that vision-led, monitor and manage, vision and validate, decide and provide, triple-access planning has been the way in which things have been done for many years. It all depends on what they really mean of course.

To date, there is scant evidence to suggest that any moves towards a vision-led transport planning approach have fundamentally reduced car dependency. Whilst there are examples, such as Poundbury in Dorset, where there have been much documented improvements in the quality of place, evidence suggests that levels of car dependency have turned out to be much the same despite using vision-led approaches.

Such enlightened approaches have never not been required. Developers have been encouraged to design housing around sustainable travel objectives for decades. The challenge is that the highway authorities generally remain unconvinced that this approach works for housing development, and regularly seek assurance that, should the vision not be realised, that there is a fall-back position where the traffic generated can be accommodated in traditional fashion on the road network.

Commonly, where a vision-led type approach is promoted, the Local Highway Authority (LHA) will require a comparable ‘full fat’ traffic assessment, and then the consultant shows what the ‘vision’ is expected to deliver. To overcome nervousness by the LHA that the vision-led approach won’t work, the developer is often then required to commit to a financial fund that the LHA can draw down on at a later stage to upgrade the highway infrastructure.

The proposed NPPF changes alone will not address the core issue identified by government of ‘designing new places defensively around worst-case highway assumptions’. The government needs to unpack this, to understand cases where this has been an issue, to develop a deeper understanding of where it matters. Recent experience is not encouraging in this regard. To date the only policy reference to vision-led transport planning has been in the National Networks National Policy Statement[7] (NNNPS). This was controversially updated in May 2024, without addressing the concerns identified[8] about the lack of clarity around what is intended by vision-led approaches (or what a ‘good’ vision looks like), or to ensure wider policy objectives such as decarbonisation are at the heart of infrastructure planning and appraisal.

I believe that substantive and sustained pressure is now going to be required to get the guidance on development planning and transport to be as watertight as needed.

In a subsequent article I’ll be pleased to look at the specific process that I believe will need to be effectively covered and codified in guidance if the proclaimed new policy approach is going to stick. I’d therefore be pleased to hear from others on what they believe needs to be put in place to make a real difference to the way we have actually done things up to now, something especially important as we look set to enter a period of unprecedented new housing development. We’ll not have another, better, chance to get this right.

Fortunately there is some useful technical work and practice that can help us shape up the necessary new guidance, and in the final section of this article, I explore that material and how it can be further developed.

What can we build on for the required guidance?

Developing clear new guidelines on transport assessment, that address policy gaps and unintended consequences, looks likely to take some time to agree - and poses challenges for both MHCLG and the DfT, given the major role it must play.

There may be optimism from government that there is an opportunity to build on work that has already been undertaken by bodies like TRICS, the Fixing Transport Assessments Working Group, Transport Planning Society, and the University of the West of England.

TRICS, in particular, has been the go-to tool in this field for several decades now. TRICS originally stood for Trip Rate Information Computer System. It was commercially launched in 1989 to provide access to vehicle movement data needed to support ‘traffic impact assessments’ (TIA). Prior to this the founding seven local authorities were each collecting their own survey data to help understand the traffic impact of new developments. TRICS was developed as a platform to share data and coordinate data collection under the stewardship of the late Dr John Latchford of JMP Consultants. TRICS originally concentrated on measuring observed road traffic to determine highways implications and to help facilitate projections for highway expansion required based on this data.

I managed TRICS between 2002 and 2008 when I worked for JMP, evolving the platform to reflect the changes in the then Government’s new planning and transport agenda. This included developing the Standard Assessment Methodology to assist travel plan monitoring and substantially increasing the number of multi-modal surveys to help provide the movement data needed for Transport Assessments (TA) following the publication of the 2007 guidelines, in contrast to the TIA approach that was dominated by concern for traffic. TRICS had been central to the predict and provide approach. Development control officers in local authorities were used to using historic traffic data to check that adequate highway capacity was being provided. The then new approach to TA encouraged the delivery of a transport vision that minimised car use and optimised accessibility by sustainable measures, supported by the implementation of a travel plan. The challenge was that there was a lack of historical data to demonstrate that vision-led transport strategies could be delivered in reality. TRICS sought to address this by building a broader database of historic data over time.

In 2014 TRICS Consortium Limited became a company wholly owned by Dorset, Hampshire , East Sussex, Kent, Surrey and West Sussex County Councils. These local authorities constitute the Board of the company, and TRICS is now project managed and delivered by a separate team based in London. TRICS has been instrumental in the planning process and decision making that have shaped settlements and associated transport provision in the UK for well over three decades. Its data has continued to be used to predict the reasonableness of TA assumptions and allow for sufficient highway provision to facilitate new development. In 2021 TRICS made bold attempts to influence its circa 400 (mainly consultancy) licensed members to encourage a departure from the way in which TRICS data is used. It published guidance on how to use the data to support a new paradigm of ‘decide and provide’ emphasising that multi-modal data only provides a benchmark based on historic trends, and this does not construe what could reasonably be delivered from the adoption and implementation of a vision-led approach.

Some local authorities like Oxfordshire County Council have adopted TA guidelines consistent with a vision-led approach, based on the TRICS ‘decide and provide’ guidance. The University of the West of England under Professor Glenn Lyons has meanwhile recently published its suggestions for a ‘triple-access planning’ approach. Somerset County Council has also been proactive, trialling vision led planning and now participating in MHCLG-funded research to define a ‘Shared Vision Led Approach’ (SVLA)[9]. The ‘Fixing TA Working Group’ led by Hampshire County Council set out its timely recommendations for TA reform to the DfT on the 24 July 2024.

The group claims[10] that “The current process is broken. All too often it enables car dependent developments that take us further and further away from our national ambition for low carbon, healthy developments where people want to live and work.” The group led by Hampshire emphasised that: “Whilst there is significant interest among local authorities in new Vision Led transport assessment approaches, with some already adopting/seeking to adopt their own guidance, far broader changes to TA guidance and related policy (NPPF) and guidance (PPG) are required to meet our policy goals. Without national guidance, this change in approach will be slow at best; but more likely, uncertainty around planning inspector support, programmes, local growth, and tight budgets will ‘water down’ or prevent change.”

Such bold statements about the significance of traffic generation from new development does rather beg the question as to why most local authorities have not considered it necessary to develop their own TA guidelines to address this issue over the last 10 years?

Oxfordshire has been pioneering in establishing requirements for decide and provide, formally adopting transport assessment requirements[11] 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.

Click to see the image enlarged.

Oxfordshire’s recommended approach for impl2e5menting ‘Decide and Provide’ requirements for transport assessment

This local policy clarification for Oxfordshire allows for more holistic approaches to transport provision. It is important to take time to explore the challenges of this approach, what scenarios are agreed and tested, and the extent to which it has been sustained following the rigours of legal scrutiny through the planning system, and from political challenge. Embedded in para 3.7.7 of the Oxfordshire guidance is reference to the need for a Section 106 Agreement that contains “a mechanism to deal with the divergence from the agreed trip scenario” if transport outcomes depart from the trajectories contained in the transport strategy. It is yet to be properly understood what these ‘mechanisms’ comprise, or whether they may provide for (Plan B) highway improvements via a back-door?

The Somerset County Council’ research to define a ‘Shared Vision Led Approach’ (SVLA) states that SVLA is suitable for all types of development planning and defines it as “a changed mindset for, and modification to, the planning process in which key actors recognise and embrace a co-operative approach to establishing and maintaining common ground that enables inquisitorial not adversarial engagement and ultimately helps expedite the planning process and deliver better outcomes”. This report emphasises the crucial importance of developing a vision that all key stakeholders can agree on, but equally raises a wide range of further complex and inter-related challenges that will need to be considered. What is less clear is how to fund the specialist resource required to achieve this in an effective manner.

Collaborative workshops would help engage local authorities and better understand the current constraints and specific challenges that they consider are hindering them from reflecting sustainable transport policy aspirations through the planning system.

There has been much debate about why TA guidance needs to be improved and considerable detail about how to address the issued identified. The big concern that government will have, is the extent to which new TA guidance might replace an outdated approach with a far more complex approach, and in doing so hinder the ability to expedite much needed new housing. Or at least be told that concern by the housebuilders.

Simplicity and getting the right balance will thus be key. We need clear statements of how the transport planning strategy proposed for a new development should demonstrate it is able to deliver the ‘place’ outcomes desired, and what are the ramifications if the agreed sustainable transport strategy fails to meet its objectives. For example, simply removing the ability to require a highway-capacity back up as a plan B, would force the onus on getting the vision, plan A, right. Any sanctions would be orientated on delivering the agreed vision rather than reverting to a highways-based approach.

It will of course be essential that MHCLG and the DfT engage with the experienced consultants who understand the practicalities of delivering housing as they will be those involved in the front line as the new approach kicks in. Theoretical concepts are useful – but as David Metz recently highlighted in his TAPAS article[12], “the formalised concept of Triple Access Planning is an idealised approach to embracing this truism, and the realities of specific geographic transport challenges, available practical options, and public and political behavioural expectations, mean the theory will be hard to deploy successfully”.

Clearly, vision-led placemaking does not in itself reduce car dependency, so it is imperative we know how to identify and decide what vision for development is appropriate, and then ensure compliance in implementation and the necessary supporting measures, for example early provision of public transport as developments progress and support to active travel. Previous attempts, for example, to ensure that travel plans were developed, implemented and monitored to a consistent standard through the creation of PAS 500[13] in 2008, were argued to be overly complex, and the specification did not have sufficient support to provide opportunity for it to be tested.

On reflection, two decades later, this level of detail may in fact be crucial to ensure that the travel plans deliver on their laudable ambitions. Poor confidence in travel plans to deliver the travel mode-shift, due to the lack of an agreed specification, has been part of the reason for a reversion back to a more predictable highways-led approach.

There are other complications. In two-tier authorities the transport aspects of a planning application are dealt with by the County-level highway authority, whilst the planning aspects are dealt with by the District. This often creates a disconnect between the placemaking objectives of the planning authority and the movement objectives of the highways (note ‘highways’, not ‘sustainable transport’) authority. The officers dealing with transport often tend to have a highways background, and changing this organisational culture will take time to filter through.

There is, in any case, a myriad of practical issues to consider when designing and evaluating the access options for new development. Whilst every development will be able to connect relatively easily with the road network, connecting to a cycle or bus network is often more complex and challenging to agree by planning condition- and putting the associated on-going funding in place, for example to support bus services at least in their early days.

Government guidance on the use of planning conditions[14] states that they should be kept to a minimum, and only used where they satisfy the NPPF-specified six tests: Necessary; Relevant to planning; Relevant to the development permitted; Enforceable; Precise; Reasonable in all other respects.

Each of these needs to be satisfied for each condition which an authority intends to apply so “otherwise unacceptable development could be made acceptable through the use of conditions”. There is significant ambiguity around these tests that have been refined through case law over many years. New guidance will need to consider where past case precedents cited have facilitated highways-led development and provide clarification on how the new policy should be interpreted in relation to appropriate Unilateral Undertakings, Section 106 Agreements and the Community Infrastructure Levy, in relation to planning obligations.

The consultation on the NPPF closes on the 24 September. It is anticipated that the DfT will then work with a renamed Planning Super Squad[15] at MHCLG to consider the responses. At present it does not appear that government have thought much beyond the review of the consultation responses in terms of how it will engage the profession and consult. It is doubtful that the people in DfT involved in creating the TA guidance over two decades ago are still there (Anthea, Natalie and Jacqui as I remember), but it will be crucial to learn from past experience. Many advisors will seek to influence government in subtle and largely undetectable ways that will be difficult to call out. In short, government will need to consider carefully who it listens to.

This is a fantastic window of opportunity for this government to be the engine for genuine change in transport planning, however the window will close quickly, and success will depend on what they hear, who advises them and how the different voices are balanced.

In interpreting the implications for vision-led planning, it is crucial that MHCLG and DfT are themselves ‘vision-led’ and have the remit to listen and shape the approach- and that they work seamlessly together on this. To achieve their housing objective government needs practical advice based on pragmatic experience of what works, and all the judgments being made - and their implications in associated areas, of which transport is a very crucial one.

It will be important for government to move at pace, to be clear on its priorities, acknowledge the additional challenges, and resist trying to address everything at once.

Fundamentally, vision-led transport planning for housing will require government to be clear on its wider vision for transport in all its dimensions. But that’s another story...

In the meantime, I’m pleased to be working with LTT/Landor and TPS to convene a discussion event on these issues in a few weeks time.

If you’d like to be involved, please get in touch!

References and Links

1. Letter from the Deputy Prime Minister to local authorities Leaders in England: Playing your part in building the homes we need (publishing.service.gov.uk)

2. Colin Black, Housing Development and Highways – will we ever break the link? TAPAS, 23 April 2024.

3. Travel Plans, Transport Assessments and Statements - GOV.UK (www.gov.uk)

4. Proposed reforms to the National Planning Policy Framework and other changes to the planning system - GOV.UK (www.gov.uk)

5. Chapter 8, A ‘vision-led’ approach to transport planning, paragraph 7. Proposed reforms to the National Planning Policy Framework and other changes to the planning system - GOV.UK (www.gov.uk)

6. NPPF_December_2023 (25).pdf → national-planning-policy-framework-draft-text-f... - Draftable

7. National Networks - National Policy Statement (publishing.service.gov.uk)

8. 28 June 2023 - National Networks National Policy Statement - Oral evidence - Committees - UK Parliament

9. Somerset Council, Delivering Better Outcomes for All – The Shared Vision Led Approach, Ministry of Housing, Communities and Local Government, Innovation and Capacity Fund Round Two Project, August 2024.

10. Fixing Transport Assessments, Phase 2 recommendations for submission to DfT and MHCLG, Fixing Transport Assessment National Working Group, 24 July 2024. PDF can be downloaded on TAPAS.

11. Implementing ‘Decide & Provide’: Requirements for Transport Assessments, Oxfordshire County Council, July 2022

12. David Metz, Triple Access Planning is a useful concept – but have the practicalities been fully thought through? TAPAS, 2 July 2024.

13. National specification for workplace travel plans, Publicly Available Specification 500: 2008.

14. Use of planning conditions - GOV.UK (www.gov.uk)

15. Gove throws £24m and planning ‘super squad’ at housing logjam (architectsjournal.co.uk)