Written evidence submitted by the Bus Users UK Charitable Trust Ltd [FPS 026]
Bus Users UK Charitable Trust Ltd welcomes the call for evidence from this Committee into how the planning system could be improved, modernised and ensure it is connected across departmental responsibilities.
Planning creates the blueprint for the quality of life, wellbeing and life chances of those affected by it. That includes not only those living or working in new development areas, but all who are affected by them.
Nowhere is this more critical than in the way transport services are designed and provided and it is crucial that this becomes a mandatory element of the design guide process.
Sustainable transport links should be a key facet of any planning system and are essential for the delivery of the Department for Transport’s decarbonisation aim to achieve net zero by 2050. These links also ensure the provision of a better quality of life for those living in areas affected by development and can therefore support the “levelling-up” agenda of this Government.
Historically, however, there has been a misalignment between new builds and the roads and services needed to make a new development part of the existing landscape. Transport infrastructure is added only as an afterthought, often by people who do not understand the way in which the surrounding communities work.
Understanding the transport needs of communities at the beginning of the planning process is essential to level up opportunities and aspirations and to reduce the incidence of social isolation, deprivation and mental health consequences that are proven to arise from living in areas without adequate public transport access.
Doing this well will require expertise in transport planning and community engagement at a senior level, to be part of an authority’s planning process under the new arrangements. We have expanded on these views in our response to the current consultation on the proposed new planning system and copy this response below as there seems to be significant crossover in the points we would like to bring to the Committee’s attention.
Response to MCHLG consultation on the Planning for the Future proposal
We have confined ourselves in this response to questions where we feel we have a direct interest and have used the consultation’s numbering system.
1 What three words do you associate most with the planning system in England?
Transport planning disconnect.
2a Do you get involved with planning decisions in your local area?
Yes, when invited to comment on large-scale developments which will have an impact on local transport networks.
3 Our proposals will make it much easier to access plans and contribute your views to planning decisions. How would you like to find out about plans and planning proposals in the future?
5 Do you agree that Local Plans should be simplified in line with our proposals?
Yes, simple processes are more accessible to everyone. However, they must include access standards for travel to and from the development area to the destinations the community suggests are important (hospitals/colleges/places of employment or leisure etc) with clear plans for public transport along with shared and active travel options.
6 Do you agree with our proposals for streamlining the development management content of Local Plans, and setting out general development management policies nationally?
Yes, but in setting the development management proposals centrally it must be made sufficiently flexible to be able to fit the aspirations and needs of local communities. One size is unlikely to ever fit all.
7a Do you agree with our proposals to replace existing legal and policy tests for Local Plans with a
consolidated test of “sustainable development”, which would include consideration of environmental impact?
This process could be streamlined, however the equalities impact assessment needs to remain part of the process. In addition, the environmental impact statement must include a consideration of the environmental impact of transport and traffic generated by the development, not just in the immediate area but more widely across local communities.
8b Do you agree that affordability and the extent of existing urban areas are appropriate
indicators of the quantity of development to be accommodated?
No, the issue is more complex. These are only two of the factors which influence house process and desirability. Others include the social premium of having good transport links, the demand for longer-distance commuting, the availability of local flexible working hubs, and time shared between two homes either for the family or children moving between parents etc. The key issue must be the requirements of the residents or anticipated residents of the particular location.
9c Do you think there is a case for allowing new settlements to be brought forward under the
Nationally Significant Infrastructure Projects regime?
No, as this requires consideration of a range of complex and inter-related issues, especially in the field of transport provision.
10 Do you agree with our proposal to make decision-making faster and more certain?
Simplification of complex processes can be useful as long as they still take account of the needs and views of the local community and what impact the new development could have on local transport.
11 Do you agree with our proposals for accessible, web-based, Local Plans?
No, web-based processes alone do not allow access to all affected communities. While new technologies allow for engagement with different communities, a range of inclusive options needs to be available.
12 Do you agree with our proposal for a 30 month statutory timescale for the production of Local Plans?
It is crucial for local communities to have sufficient time to assess the practical impacts of development zones in the Local Plan. Much of this will involve transport and other infrastructure provision. Allowing six weeks, or 5% of the total timescale, for this crucial part of the process is clearly insufficient.
13a Do you think that Neighbourhood Plans should be retained in the reformed planning system?
13b How can the neighbourhood planning process be developed to meet our objectives, such as in
the use of digital tools and reflecting community preferences about design?
This is a question for local communities, bearing in mind that many communities have little or no access to the internet and vulnerable groups may be excluded.
16 Sustainability is at the heart of our proposals. What is your priority for sustainability in your
The Department for Transport’s policy paper Decarbonising Transport – setting the challenge published in March 2020 made less reliance on cars a central policy pillar of reaching net zero by 2050. In order to achieve this, it is essential that all new developments should be expected to take account of public, shared and active travel options, accessible to all residents. Without these, permission should not be granted.
17 Do you agree with our proposal for improving the production and use of design guides and codes?
It would be useful to produce such guides although we would want to see a wider definition than simply the design of the building stock. Design guides should include a means of demonstrating evidence of local engagement, proof of demand for access and mobility, and how it is intended this should be satisfied through the design of transport services.
18 Do you agree that we should establish a new body to support design coding and build better places, and that each authority should have a chief officer for design and place-making?
Reference has been made in our answer to question 16 to the Department for Transport’s policy proposals for reaching net zero transport emissions by 2050. Transport is the major source of pollution in the country and therefore it is essential that any reform to the planning system puts this at its heart. We advocate the case for a Chief Officer appointment to be broader than design and place-making, but also to lead and take responsibility within the lower tier authority where relevant policy is the responsibility of another authority to ensure that its delivery is timely and relevant for the developing area. To do otherwise would be a missed opportunity and would frustrate the aims of the planning process simplification.
19 Do you agree with our proposal to consider how design might be given greater emphasis in the strategic objectives for Homes England?
Design must include accessibility to, from and within the development. It must also, therefore, include standards laying down bus and coach facilities and access rights, as well as ensuring shared and active travel opportunities are considered in collaboration with the local communities affected. Access to cul-de-sacs is complicated and awkward for many forms of transport, including emergency services and many types of public and community transport vehicles, so this model should be avoided in favour of providing safe community space nearby.
20 Do you agree with our proposals for implementing a fast-track for beauty?
No. The key element of any development is understanding how it affects its own residents and the communities around it. Appropriate community engagement and high-quality transport planning take time, so fast-tracking developments would not lend itself to understanding and mitigating impacts. Aesthetic considerations are important, but subjective, so should never be the driving force.
21 When development happens in your area, what is your priority for what comes with it?
Our priority is that all communities and all their members have access to sustainable transport options which suit their needs. No new developments should be planned in a way that is only suitable for car users, particularly if the aim of net zero emissions by 2050 is to be achieved.
22a Should the Government replace the Community Infrastructure Levy and Section 106 planning
obligations with a new consolidated Infrastructure Levy, which is charged as a fixed proportion of development value above a set threshold?
We have noted that some local authorities are reluctant to engage with Section 106 planning conditions to provide transport services. So long as the new Infrastructure Levy is specifically mandated to be for the provision of services as well as built infrastructure then we would support it. If not, then the section 106 provisions must be strengthened to ensure proper levels of transport provision are hard-wired into development proposals.
22b Should the Infrastructure Levy rates be set nationally at a single rate, set nationally at an area-specific rate, or set locally?
The levy should reflect local circumstances and community aspirations. A formula should be provided nationally which would allow this to be calculated locally and be made transparent to the local communities affected.
22d Should we allow local authorities to borrow against the Infrastructure Levy, to support infrastructure delivery in their area?
This would seem logical as long as funds borrowed are ring-fenced to be used for infrastructure for the development area. In that case, the funds borrowed should only be used to ensure delivery of services from first occupation before the Levy would otherwise be collected from the developer.
24a Do you agree that we should aim to secure at least the same amount of affordable housing
under the Infrastructure Levy, and as much on-site affordable provision, as at present?
This should be the subject of agreement with the local communities as part of the community engagement process.
25 Should local authorities have fewer restrictions over how they spend the Infrastructure Levy?
There should be a template of required minimum standards of infrastructure to be provided so that developments cannot avoid or subvert their wider responsibilities. We have noted that in some lower tier authorities there is a reluctance to use developer funding to provide or promote public transport. One reason is that they can use it to ensure higher car use which leads to increased car park or residential parking permit income for them.
26 Do you have any views on the potential impacts of the proposals raised in this consultation
on people with protected characteristics as defined in section 149 of the Equality Act 2010?
Wherever possible, developments should enable step-free access to the property from the nearest sustainable travel option(s), rather than just the nearest point at which one could alight from a car.
Adequate planning consultations should not be undertaken until an in-depth equalities assessment has taken place and all local representative bodies have been invited to comment, and those comments considered and fed into the proposals where pertinent.
By engaging communities at an early stage, this will reduce the number of objections to developments as long as that engagement is serious and productive, rather than a tick-box exercise. This will also result in local championing of new developments, rather than the local authority having to marshal arguments against a small vocal minority.
More importantly, a new inclusive planning process will ensure a higher quality of housing and commercial stock in the longer-term, designed with its environment and the community in mind, and ensuring that all who use the development can access it from wherever they start their journey.
About Bus Users
Bus Users campaigns for inclusive, accessible transport. We are the only approved Alternative Dispute Resolution Body for the bus and coach industry and the designated body for handling complaints under the Passenger Rights in Bus and Coach Legislation. We are also part of a Sustainable Transport Group of organisations working to promote the benefits of public, shared and active travel.
Alongside our complaints work we investigate and monitor services and work with operators and transport providers to improve services for everyone. We run events, carry out research, respond to consultations, speak at government select committees and take part in industry events to make sure the voice of the passenger is heard.
Bus Users UK is a registered charity (1178677 and SC049144) and a Company Limited by Guarantee (04635458).