As promised, the consultation draft of the proposed new NPPF was released yesterday. We have until 23:45 on 24th September to respond. There is also some explanatory text published alongside the tracked-changes consultation draft.
As a Transport Planning consultancy, we have be drawn to our familiar āChapter 9 Promoting sustainable transportā to see what is proposed.
The first six paragraphs of Chapter 9 are proposed to be unchanged, save for new paragraph numbers. The changes come under the heading āConsidering development proposalsā. Whereas traditionally the approach has been to āpredict and provideā (i.e. forecast the future traffic scenario and provide infrastructure and measures to accommodate it, usually in the worst-case peak hour conditions), the proposal is to take a āvision-ledā approach.
We are already familiar with the concept of focussing on a vision, from National Highwaysā Strategic road network and the delivery of sustainable development (23rd December 2022) which requires Transport Assessments to start with a vision of what the development is seeking to achieve and then test a set of scenarios to determine the optimum design and transport infrastructure to realise this vision.
The accompanying text to the consultation draft explains the thinking behind the āvision-ledā approach to transport planning:
At present, planning for travel too often follows a simplistic āpredict and provideā 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 āworst caseā 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 āvision-ledā transport planning and, unlike the traditional āpredict and provideā approach, it focuses on the outcomes desired, and planning for achieving them. To support this approach, we are proposing to make amendments to paragraphs 114 and 115 of the existing NPPF. To support the implementation of this updated policy, we will publish updated guidance alongside the policy coming into effect.
The proposed new NPPF paragraph 112 (currently 114) introduces the vision-led approach and reads:
āIn assessing sites that may be allocated for development in plans, or specific applications for development, it should be ensured that:
- A vision led approach to promoting sustainable transport modes is taken, taking account of the type of development and its location;
ā¦
- any significant impacts from the development on the transport network (in terms of capacity and congestion), or on highway safety, can be cost effectively mitigated to an acceptable degree through a vision led approach.
The key paragraph which we transport planners know oh so well, paragraph 115 and the question of āsevereā impact, is proposed to be modified with four new words at the end which are likely just as contentious as the use of the word āsevereā:
āDevelopment 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, in all tested scenarios.ā
This is likely to be the biggest change for us and our clients. Whereas we have previously tested the effect of a proposed development in the forecast future peak-hour traffic scenarios, and, where this is severe in any of those scenarios we have sought to mitigate it, the new expectation is that the impact has to be severe in all scenarios for it to be refused on highways grounds. In other words, it will be harder to justify a refusal if the traffic impact is not severe in every assessment scenario.
No doubt the promised updated guidance on this policy will make things clearer and will set us all on the right path to achieving more sustainable development.
We welcome these proposed changes and look forward to seeing the outcome of the consultation and the adoption of the new NPPF, which is promised before the end of the year.
If you have a development vision and would like to discuss how we can help achieve that vision, get in touch!