The 1994 revision of Planning Policy Guidance Note (P.P.G. 13) on Transport was a landmark in British transport and planning policy. Jointly issued by the then Departments of the Environment and Transport, it set the new ground-rules for moving to a sustainable land-use and transport system. The hallmarks included the new objective of reducing the need to travel, planning for public transport, walking and cycling, increasing residential densities and curbing out-of-town development. It didn't go as far as many wished, but has been a vital document nevertheless.
Now P.P.G. 13 is being reviewed again, in the light of five years of practice, debate and changing policy. Since the 1994 revision, we have seen a change of Government and a new transport White Paper, the merger of ministries into the Department of the Environment, Transport and the Regions (D.E.T.R.), two damning transport reports from the Royal Commission on Environmental Pollution, official admission (in the form of the Standing Advisory Committee on Trunk Road Assessment) that new roads generate traffic and are not essential to economic prosperity, the Kyoto agreements on limiting climate forcing emissions, the passing of two Road Traffic Reduction Acts (if in a watered-down form), and no let-up in traffic growth.
Given this apparent paradigm shift in official transport thinking, one would expect the draft revised P.P.G. 13, on which consultation has just finished, to represent a step-change of a magnitude similar to that in 1994. Unfortunately, it doesn't really achieve that. Indeed, in his letter which forms the preface to the consultation draft, the D.E.T.R.'s Jeff Channing makes it plain that the revision is designed to promote better integration and achieve "more consistent implementation of the existing policy approach".
The objectives of the revised document are to "promote more sustainable travel choices, and reduce the need to travel, especially by car". These are very laudable aims, but they do not move policy any further than the existing P.P.G. 13. In particular, the objective of reducing the need to travel needs to be expanded to become a clear statement of fostering a reduction in motorised travel. Similarly, the close link between car ownership and use is not recognised, despite the fundamental association of that link with parking standards and development densities.
Throughout the Note, the language is weak. For instance, local authorities "should consider" redistributing road space, "give consideration" to a mix of uses in new development, and "seek to meet" the needs of disabled people by "taking account of" and "giving attention" to them. Likewise, there are several places where ambiguity could be avoided by emphasising sustainable or non-car travel choices.
Important factors in encouraging people to use non-car forms of transport are frequently missed, such as the need for convenience and attractiveness with walking and cycling routes, and accessibility on high-quality bus routes (which goes beyond the vehicles). There are significant omissions in the measures suggested for local authorities to promote as well. Public transport promotion, car-free housing and encouraging lower car ownership are missed out of the 'main planning policies section', as are the needs of women.
Other curious omissions include:
One very positive inclusion in the consultation draft is the move to setting maximum parking standards (rather than minimum). However, the actual national standards proposed appear very lax, and seem to have been set so as not to inconvenience developers. They are not by any means challenging and are in places rather strange: food retail is for some reason allowed more parking per square metre of gross floorspace (more display space may, in cases such as furniture, be needed, but the likelihood of arriving by car is also higher in such cases). Thresholds are proposed, below which local authorities would be able to set their own, independent standards, but no explanation is given for their seemingly arbitrary levels. Perhaps of greatest concern, however, is that parking standards for new housing are completely absent!
Large retail and leisure developments see tighter locational regulation in the draft, with out-of-centre sites only being countenanced if they have good public transport and "where there is a clearly established need for such a development". There is no indication as to what is to be taken as proof of need, and none of on whom the onus of proof would rest (developer or local authority). It is perhaps instructive that the Secretary of State has recently allowed major out-of-centre developments on vague grounds of 'regeneration' above planning policies. At the end of the day, the operation of the "sequential test" for large retail and leisure location is so much like rearranging of deckchairs on the Titanic. Large-floorspace retail and (to a lesser extent) leisure developments tend to attract heavy car use wherever they are located. What is surely needed is an awareness of this scale issue and the imposition of an upper limit on retail (in particular) floorspace.
Whereas the onus as regards the justification or otherwise of out-of-centre retail appears to favour developers, the onus is already firmly on the developer, and the cards are stacked against them, when it comes to housing for people working in agriculture and other land-based activities in rural areas. The retained inflexible presumption against sporadic housing in the countryside actually serves to increase the need for travel, in the form of out-commuting from towns and villages.
In a document produced by a Government which espouses "joined-up thinking" one expects joined-up policies. But rhetoric here is not backed up by anything solid. The plentiful holes in the proposed policies and strategies are exemplified above. Ensuring access for disabled people, a moral imperative under the Disability Discrimination Act 1995, is mentioned, but fails to be integrated into the core of the new strategy. Likewise, health is presented as a key reason for planning for more sustainable travel, yet the links to Health Action Plans are missed, let alone the need to keep health facilities centrally located and to resist the closure of smaller, local units. The same goes for small schools, shops and other services.
In conclusion, P.P.G. 13 should have come a long way in five years. The fact that it hasn't surely demonstrates that the current Government, despite its rhetoric, is making much less progress on sustainable planning and transport than its predecessor.