Written evidence submitted by the Campaign for Better Transport [NPP 35]

Summary

1. Campaign for Better Transport supports the overall objective of high density residential development around public transport hubs. We are concerned that proposed amendments to National Planning Policy will fail to maximise the benefits that such an approach can bring. To rectify this, the following amendments should be made:

• Take steps to define appropriate residential density
• Give clearer guidance on what a commuter hub consists of
• Ensure clearer link with strategic land use planning processes
• Provide further support for the delivery of higher density development around public transport hubs

Benefits of residential development based around transport hubs

2. Campaign for Better Transport welcomes the opportunity to contribute to the Committee's inquiry. DCLG's consultation on National Planning Policy covers a wide range of themes. Our response to the Committee focuses on transport policy, and in particular proposals to increase residential density around commuter hubs.

3. We support the overall objective of increasing housing density around commuter hubs. There is strong evidence that employing such an approach can support a range of positive policy outcomes. These include:

• Reduce car dependency in existing settlements - Opened in 2007, regeneration of the Princesshay area of Exeter integrate transport into wider planning. It included new residential units and a pedestrianisation scheme which removed 3,000 vehicles a day from the city centre. This was supported by improvements to highways and public transport facilities and created new space for an improved cycle way and footway. (http://www.academyofurbanism.org.uk/princesshay/)

• Supporting more sustainable transport in new developments - Shawfair is Scotland’s first new town in 50 years. It is being constructed on the outskirts of Edinburgh with a station on the re-built Borders Railway at its centre. When completed, Shawfair will have 4,000 houses, three schools, and shopping and leisure facilities and will offer a journey time to central Edinburgh of under 10 minutes. The station is already in operation - before the housing is complete, meaning sustainable patterns of mobility can be established as new residents move in.

• Improving public health – The Cambridge guided busway links Cambridge’s growing commuter belt with major employment and retail areas of the city. Recent research has found that the opening of the busway has significantly increased active commuting, particularly among those previously least likely to take it. It strongly supports the reconfiguring of transport systems as part of public health improvement strategies (https://www.repository.cam.ac.uk/handle/1810/251056?show=full)

4. We are concerned that DCLG's proposed changes to planning guidance do not go far enough in bringing about such benefits. Without further clarification and supporting information is needed to overcome the problems set out below.

Encouraging reactive and opportunistic development

5. Government proposals can be characterised as encouraging new, high density residential development around the existing commuter rail network. As can currently be seen in proposals around Guildford (http://www.getsurrey.co.uk/news/surrey-news/residents-scrutiny-group-criticise-150m-10690114), there are risks to such an approach which Government must take steps to minimise. These include:

• A focus on existing, often heavily used transport hubs and commuting routes, rather than the development of new or lightly used public transport hubs to support new patterns
• Taking place at a stage removed from planning on the existing rail network, where commuter services have seen huge growth [http://www.bettertransport.org.uk/maps/rail-usage.html] and now suffer overcrowding and shortages of rolling stock at peak times

Fail to identify appropriate residential density

6. The objective of the Government's proposal is to require local planning authorities to deliver higher density residential development around commuter hubs, which combine rail, tube or tram with buses, walking or cycling.  In so doing, Government explicitly rejects the need for national guidance on what 'high density' should entail, instead making this a matter for local authorities alone.

7. Density is a contested area and we accept that one-size-fits-all definitions are unhelpful and potentially counterproductive. As the Town and Country Planning Association has noted, increasing density can "lead to such undesirable outcomes as the omission or loss of urban open space, localised congestion, excessive noise, and a general loss of amenity such as light, sunshine, and a view of the sky." [http://www.tcpa.org.uk/data/files/densities.pdf]

8. As a counterpoint, however, overly simplistic changes to planning guidance risk simply introducing the idea of increased density around commuter hubs without offering the means to judge how it should be achieved. In such circumstances, it is possible that deciding appropriate density will be left to developers, an approach which may not result in the optimum outcomes.

9. To overcome this, we would recommend that Planning Practice Guidance should set out a basic methodology for establishing an evidence base on appropriate density. This should include examples of good practice, consideration of employment patterns and housing need, and consultation with local residents, Network Rail, train operating companies and other public transport providers.

Lack clear links with wider strategic land-use planning

10. Effective land-use planning is central to supporting commuter hubs. We are concerned that a policy of encouraging higher density residential development around rail stations will not on its own achieve all the potential benefits. To achieve this, there is a requirement to connect transport planning and wider land use planning. Two examples of where such an approach has been employed are detailed below.

11. The Black Country Core Strategy was adopted by Dudley, Sandwell, Walsall and Wolverhampton in 2011 and shows how sustainable transport and growth can be pursued strategically through the local plan process. The strategy aims to support high quality development sites (including residential) largely through investment in public transport. All new developments are required to provide adequate access for all transport modes (in effective, creating new public transport hubs) with priority being given to improving transport in key corridors by improving public transport, traffic management and facilities for cyclists and pedestrians. Commuters are identified as a particular target, with efforts focusing on shifting workers from cars to more sustainable modes. The document also sets out key transport infrastructure priorities including extending the Midland Metro to connect main centres to each other and to Birmingham and delivering a Quality Bus Network across the Black Country.

12. The South Yorkshire Passenger Transport Executive has developed a traffic light classification system known as LUTI (Land Use and Transport Integration). This scores development sites according to their accessibility by public transport to assist developers in ensuring that sites are well served by public transport or, if not, that the necessary provision can be made:

• 'Green sites' are those located within acceptable distance of the core public transport network (defined as 400m from a bus stop or 800m from a train or tram service). These are suitable for high density development.
• 'Amber sites' are located partly within an acceptable distance and may require intervention to ensure they are accessible by public transport.
• 'Red sites' are entirely outside the acceptable walking distance and are likely to require intervention to improve access to public transport and allow development to proceed. Intervention could mean diverting or enhancing a public transport service or providing a new one and the developer could be required to fund such an improvement at least for an initial period – this too could qualify as an appropriate site for high density development.

Better guidance on what a commuter hub is

13. If the proposed changes are to result in more than simply building flats around existing commuter rail stations, planning guidance needs to offer more guidance on what constitutes a commuter hub. This should contain the following elements:

• As well as rail and tram, guidance should make clear it is permissible to base hub development around high quality bus networks
• Good cycling and walking links should be a central part or planning for new public transport transport-centred development along with limitations on levels or car parking. This would help to ensure a higher overall proportion of journeys are taken by sustainable modes, not just journeys to work 
• Scope should be available for new residential development beyond half a mile of a commuter hub where good cycling and walking facilities make this viable
• Safeguards should be in place to ensure any rail land being considered for development is protected for future rail use first wherever there is a case for doing so
• Towns of below 25,000 should be eligible for inclusion where strong demand for sustainable commuting can be demonstrated.

Supporting delivery

14. We welcome moves to enshrine support for high quality residential development based around public transport hubs in planning guidance. More support is needed to encourage the take up of such development: This should include the following aspects:

15. Central Government should establish a specific fund to support rail-based schemes that requiring the upgrading of rail services, or the opening or reopening of rail stations and lines. Such a fund could be based on an expansion of the Governement's New Stations Fund, which we previously called for. http://www.bettertransport.org.uk/sites/default/files/research-files/reopening-railways-report.pdf

16. Further guidance is needed on how new development can be planned, located and managed to promote sustainable transport habits. Our Sustainable Master Planning Checklist provides guidance on how this can be achieved, including a minimum density of 200 dwellings per hectare for sites with excellent access to public transport and the need to for travel plans to support new residential development. (http://www.bettertransport.org.uk/sites/default/files/research-files/Masterplanning_Checklist_2008.pdf)

17. Where a local authority has identified the potential for high density development around a new or existing public transport hub, a development partnerships should be established to promote high quality development. This should involve the local authority, developer, public transport providers, relevant employers and those representing relevant community interests. Such a partnership should be invested with the powers to buy land if necessary. 

January 2016

Campaign for Better Transport is the UK's leading authority on sustainable transport. We champion transport solutions that improve people's lives and reduce environmental damage. Our campaigns push innovative, practical policies at local and national levels. Campaign for Better Transport Charitable Trust is a registered charity