Written evidence submitted by the Urban Mobility Partnership [FPS 122]
About the Urban Mobility Partnership and reasons for submission
The Urban Mobility Partnership (UMP) is a coalition committed to providing long-term leadership and near-term solutions to improve future mobility. The group was founded to ensure that effective policy at a national, regional, and local level, combined with new technology, supports better mobility and helps tackle the major challenges of congestion, air quality and decarbonisation.
The membership of the Urban Mobility Partnership; consisting of Enterprise, Stagecoach, Bosch, nextbike, Mobilleo, Foot Anstey and Brompton Bike Hire; covers the breadth of the mobility landscape and combine for over a billion consumer journeys a year across the UK.
UMP is committed to helping to develop mobility solutions which help towns and cities transform how consumers travel. The group draws upon its member’s expertise from across the mobility sector and ‘on the ground’ knowledge to develop solutions which can be implemented within the short to medium term, rather than looking ahead to the next 25 years.
UMP is submitting evidence to the future of the planning system in England inquiry because of the significant ramifications the planning system has for the UK’s ability to create a future connected and sustainable multi-modal transport system that places the consumer at its heart. The planning system and the proposed government reforms will also have an impact on how well the UK tackles key transport challenges such as air quality, carbon emissions and congestion.
This response draws attention to elements of both the current planning system and the proposed reforms which require changes in order to support truly sustainable development and the government’s wider ambitions to combat climate change, congestion, air pollution and poor connectivity.
The role of mobility in sustainable development
A key concern of the Urban Mobility Partnership with both the current planning system and the government’s proposed reforms is a lack of specific consideration for mobility, a key factor in making progress towards the UK’s environmental targets such as achieving net zero by 2050.
The Government places a significant emphasis on promoting sustainable travel in its developing Transport Decarbonisation Strategy, the ‘Gear Change: A bold vision for cycling and walking’ strategy and the Secretary of State for Health’s Vision for Prevention, which highlights the importance of connecting housing and transport in order to improve the nation’s health.
The proposed reforms provide a much-needed opportunity to effectively integrate planning and transport policy. The government’s emphasis on sustainable travel elsewhere must be matched in these reforms to build the sustainable multi-modal transport system of the future and achieve the government’s housebuilding targets. As without consideration for sustainability and infrastructure and the development of sustainable communities, local opposition to increases to congestion and pollution created by unsustainable development will be a barrier to housebuilding.
Requirements on developments
Given the government’s policy focus on sustainable mobility, a key tenet of any reform to the planning system should be aiming to create developments that reduce consumer reliance on the most polluting forms of transport and encourage modal shifts amongst residents to sustainable forms of transport. Whilst there is reference within the White Paper to maximising the ability to walk and cycle within developments in ‘Growth areas’ a number of other specific requirements on developments are required to make truly sustainable communities:
- There should be specific requirements to ensure that not only is there the requisite road infrastructure to support walking and cycling; pedestrian walkways, cycle lanes and paths, but there is also access to bike hire and bike share within significant new developments in ‘Growth areas’. Access to these should not come at the expense of pedestrian areas and the planning system should priorities sustainable modes such as bike hire and bike share for example over private car parking space – too often in the existing system local authorities try and avoid installing bike share stations in parking spots and prefer to install them on the pavement which is influenced by the fear of "taking away people's parking". This instalment on the pavement is at the detriment to other forms of active travel and is often a significant concern to residents who then reject to bike share stations
- Walking and cycling infrastructure needs to be integrated with sufficient public transport, particularly bus, and other shared modes such as car club and daily rental which can accommodate for journeys that cannot be completed by active travel and for residents that need access to other modes such as the elderly
- There should be specific requirements for public transport and shared transport to reduce the reliance on the private car and free up road capacity for active travel, making these modes safer and more attractive to the wider community. Furthermore, by reducing the overall use of cars, these modes will result in less congestion, improving the efficiency of bus corridors. Similarly, wider modal shift towards bus travel would accommodate growth without unsustainable and unaffordable major roads schemes
- Sustainable transport priority measures should be included within new developments. Developments should prioritise bus and cycle lanes and guided busways (open to other forms of shared mobility), implement and connect to park and ride/ park and pedal (which include car club and daily rental) facilities, and give priority to sustainable transport at junctions.
By also implementing innovative dynamic traffic management measures, alleviating potential congestion hotspots, road transport would move more efficiently within new developments and on the roads around it - decreasing the need for cars to stop and start, in turn further reducing emissions.
These measures would not only dramatically reduce congestion and emissions but would also help to overcome some of the image related issues with public transport by increasing the efficiency of bus travel – further driving modal shifts away from private car use. In addition to this, it has been shown that the economic benefit for priority measures, for buses alone, can deliver almost £5 of economic benefit per £1 of government spending.
Embedding sustainability at a national policy level
National planning policy must address more explicitly the aspects of delivering sustainable communities referred to above and which are vital in addressing some of the seismic changes in living and working habits that will ensure as a result of the current pandemic. The recommendations of this submission are that:
- There is clear focus and setting of standards for sustainable mobility in the National Model Design Code and the legislation required for new Local Plans, with established definitions of what constitutes ‘sustainability’ and ‘mobility’ and a requirement for access to a wide variety of shared and public transport modes included within new developments
- In designation of whether an area is suitable for development should include a specific requirement that land defined as renewal or growth can make sustainable modes of transport more attractive than single occupancy private car use. This includes ensuring that large developments are placed on high quality bus corridors
- The government must incorporate the concept of multi-modal ‘mobility hubs’ within the National Planning Policy Framework and National Model Design Code.
Mobility hubs are places of connectivity where different travel options – walking, biking, car, bus and more - come together. These hubs can range in size from locations which incorporate all of the aforementioned modes to a simple bus stop which has a bike sharing rack connected to it. They not only help to provide connected access to a range of sustainable modes of transport, including public transport, but can also redesign parking areas and public spaces to encourage the shift away from private car use. The predominant benefit of these hubs is that they provide seamless connectivity between modes and between different areas of a city, town or local area. A managed network of hubs can also provide real time data to consumers, transport providers and local authorities.
A fundamental weakness of the current system is that local plans are not living documents and rapidly cease to be fit for purpose. The proposed streamlined local plan system in the government’s reforms does not address this weakness. Further, while the proposed sustainability test for local plans would include environmental considerations, it is vital it promotes consistency and considers key transport concerns.
UMP recommends that:
- The logistical and practical hurdles associated with revising entire local plans from time to time could be addressed through a local plan system made up of a core local plan alongside specific supplementary documents covering rapidly evolving policy areas. These supplementary documents would be capable of rapid and individual revision to address changes in living and working habits and the national and global policy agenda such as decarbonisation alongside the role that innovations such as mobility hubs play in addressing such matters. However, by retaining a core local plan this avoids difficulties aligning planning targets such as housebuilding with more evolving areas such as infrastructure.
- The proposed sustainability test for local plans develops a consistent approach to requirements on developers as they pertain to mobility solutions. This is particularly important given that the white paper states that any sustainability test would include environmental considerations. We would recommend that this be more specific and take into consideration key mobility issues and how air quality can be improved.
Using developer contributions to their full potential
The Community Infrastructure Levy and contributions made under S106 are often of narrow scope, limited to funding improvements to existing travel infrastructure or facilities rather than providing high quality, multi-modal connectivity in new developments that could influence consumer behaviour change. For example, contributions might fund a single mode of transport for the residents of a development which does not best suit their needs and circumstances rather than a "mobility credit" that could be redeemed for any number of transport modes would be more suitable.
There is also a structural issue around the planning application process which may provide too much time flexibility, allowing the negotiation of Section 106 agreements to be dragged out by all parties. The result is often that the required contributions are negotiated down due to viability issues. The proposal to remove Section 106 agreements does not really address this.
The White Paper does suggest that local authorities should be given more freedom as to how they spend developer contributions. However, often authorities do not have the expertise or the resources to effectively use developer contributions and the planning and thinking between departments is often disjointed and ‘siloed’ without consideration for one another’s goals.
To combat the above issues and strengthen the government’s reforms to developer contributions UMP recommends:
- A prioritisation of sustainable transport and clear consistency as to how developer contributions are spent, in line with the requirements within design codes and local plans discussed above that ensure sufficient deployment of mobility solutions. Currently the sustainable transport is at the bottom or near the bottom of priorities for developer contributions. This must change if the other reforms discussed are to be effective, particularly embedding the concept of mobility in national and local planning policy
- A more stringent statutory time period for determining planning applications such as those in relation to the Nationally Significant Infrastructure Planning regime to help resolve the dragging out of negotiations. A more effective land value capture process would also address the viability issue caused by landowners not having to share the burden of Section 106 obligations in the land price
- Local authorities should be offered additional support from central government on how to effectively use developer contributions and be required to work with sustainable mobility providers to establish the best solutions for their communities
The implementation of multi-modal solutions within developments would significantly contribute to improving air quality and reducing congestion but could also increase the value of developments. Consumers are increasingly looking for ways to travel both sustainably and actively. If this opportunity is seized by both government and developers, it can be a net gain for both and secure long-term benefits.
UMP recommends the following innovations, which would support the development of a multi-modal transport system and increase modal shift away from private car, for guidance on developer contribution spending:
- ‘Mobility credits’ schemes - This is a scheme that reduces the number of cars on the road, particularly older more polluting vehicles, by offering a credits-based incentive scheme for use on all local sustainable transport options. Funds generated through developer contributions could be provided to new residents in the form of ‘mobility credits’ to incentivise them to use sustainable modes which have been integrated into a new development. There is also the option to combine mobility credits with a scrappage scheme which can further reduce the need for a private vehicle
- Mobility as a Service (MaaS) Solutions - MaaS is a response to the need articulated by consumers for transport to be on-demand, multi-modal and convenient. The use of digital platforms is essential in facilitating this shift, allowing consumers to plan, book and pay for journeys using a mobile app. In addition to transforming how consumers travel, MaaS can provide additional benefits by reducing congestion, improving air quality and ensuring better links from a new development to existing areas of a city, town or region