The end of 2024 brought us the highly anticipated revisions to the National Planning Policy Framework (NPPF), and with it, hope of a smoother planning journey…. As the dust settles on its arrival, we share our thoughts on the transport and highway implications of these national policy changes.
The Overall Theme
In keeping with the overall theme within the NPPF of the ‘presumption in favour of sustainable development’, and ‘promoting sustainable transport’, the key objective of promoting walking, cycling and public transport has been retained. The need to prioritise pedestrian and cycle movements first, followed by public transport is also still mentioned in the latest version. This hierarchy has been at the forefront of transport policy for a while, and it is welcoming to see this maintained to achieve the sustainable development theme!
Another key theme is the recommendation of early engagement on transport considerations with local communities (and presumably highway authorities). We always seek to involve ourselves in the very early stages of the design process and see this early engagement as a crucial element for all but the smallest schemes. The recent changes to the NPPF make this even more critical for larger schemes.
The main changes in terms of transport and highways within the NPPF are the introduction of the terms ‘vision-led’ and ‘reasonable future scenarios’ in Chapter 9 ‘Promoting Sustainable Transport’.
Vision-led Transport Planning
The first paragraph of Chapter 9 highlights the need for a ‘vision-led’ approach to identify transport solutions that deliver well-designed, sustainable and popular places.
The definition of the ‘vision led approach’ in the NPPF glossary states that it is ‘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.’
Given the overall theme of promoting sustainable transport, the vision should be to minimise the number of private car movements and create places/developments that encourage active travel and public transport.
‘Vision-led’ may appear to be a new addition to the official planning vernacular, however, this term or variants of the term have been discussed in transport planning circles for quite some time.
It gets to the heart of “what type of development/place do we want, how do we want people to travel to/from it and how can we make this happen?"
The hope is that this is the “nail in the coffin” for the ‘predict and provide’ approach, which essentially involves estimating the transport impact of a development by assuming historic travel patterns without any mitigation, and then providing sufficient highway capacity to address this scenario. No vision, just a resignation that things will always remain as they have been.
There has been a long-standing acknowledgement that if additional highway capacity is provided, the road network becomes more attractive to drivers and the additional highway capacity is rapidly used up. It is a self-fulfilling prophecy – “if you build it, they will come..”. However, it is not always recognised that this should apply to non-car modes - developments designed to provide safer and more convenient access to sustainable modes of transport should result in a higher share in these modes, achieving the NPPF’s overarching aims.
Chapter 9 also refers to “popular places”. We are unsure how this will (or can) be defined, but presumably a key measure of popularity will be how much travel and activity occurs at the development. In other words, will people want to live in, work at and visit these places? I’m sure it will be in the developer’s interest that this happens.
Reasonable Future Scenarios
Paragraph 116 of the NPPF notes 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.
The NPPF glossary defines ‘reasonable future scenarios’ as follows:
A range of realistic transport scenarios tested in agreement with the local planning authority and other relevant bodies (including statutory consultees where appropriate), to assess potential impacts and determine the optimum transport infrastructure required to mitigate any adverse impacts, promote sustainable modes of travel and realise the vision for the site.
A key point here is the agreement with statutory consultees on the transport scenarios to be tested. This goes hand in hand with the early engagement recommended in Chapter 9, and the importance of agreeing a way forward on the transport aspects of a scheme and the scope of the assessments at an early stage.
We already agree future scenarios with highway authorities. The Travel Plans we prepare to support developments reflect the very essence of a vision-led approach, as they set targets for how people should travel to a site and then propose measures to achieve those targets.
The nature and number of reasonable future scenarios is likely to be influenced by the size and complexity of the proposed development. At a basic level, this involves:
1. Explaining and agreeing the overarching transport vision with local authorities;
2. Understanding current travel patterns in the area;
3. Assessing potential future travel patterns/trends;
4. Setting out the key outcomes of the vision (for example in terms of the transport mode share); and
5. Establishing (and agreeing) the transport infrastructure and measures required to achieve the vision and associated outcomes.
The above should, in principle, lead to agreement of the reasonable future scenario(s). Agreeing the measures required to achieve this vision will be key, requiring an evidence-led approach.
Unfortunately, whilst local authorities often accept the vision and seek a range of measures to assist in achieving the outcomes, they also insist on the testing of a “worst-case” scenario. This usually involves a scenario where the proposed mitigation has no (or little) effect on travel patterns (“just in case”), despite evidence to the contrary.
On the flip side, there will be a requirement for developers to ensure that the transport infrastructure is sufficient to achieve the vision, i.e. a significant reduction in car trips won’t just happen by itself.
Pulsar’s Conclusion
Inevitably, the revised NPPF will be open to interpretation and no doubt will be tested at various Appeals. Our belief is that the revisions are positive and will avoid the “worst case scenario” testing previously required. It also promotes a more collaborative approach with highway authorities. It should “move the needle” away from purely highway capacity focussed solutions and towards a sustainable transport vision.
However, agreement on what constitutes a reasonable future scenario is likely to form the new battleground, along with familiar disagreements on the effectiveness of mitigation and whether the proposals will lead to a severe impact.
If you would like to find out more on the new vision-led requirements, or how we can assist you with your schemes, please do not hesitate to get in touch. We’re looking forward to working with new and existing clients in 2025 and beyond, creating sustainable and popular places to live and work.