1. The Planning Officers Society has membership drawn from the Chief Officers of local planning authorities in England and Wales.

OVERALL DIRECTION

  2. The Planning Officers Society made representations to government in response to the consultation document and greatly welcomes the extensive recognition given in the White Paper to the measures advocated by the Society. The policies contained within the White Paper represent a sea-change in national policy.

  3. In welcoming the government's policy to bring to bear a wide range of policies and techniques to achieve an integrated whole, the society recognises that its expertise lies in the contribution which the planning system can make to this process and thus its following comments are limited to that area.

  4. For the reason that the White Paper represents a substantial redirection of public policy, much work remains to be done to apply the new policy direction in practice. The Planning Officers Society stands ready to assist in this process.

  5. The Planning Officers Society presented the view that previously too great a reliance had been placed on the planning system alone to deliver fundamental changes in society's attitudes towards transport. It called for the planning system to be supported by a redirection of the full range of government powers and policies in a co-ordinated fashion. The Society welcomes and supports the extent to which this is proposed in the White Paper.

  6. In two instances, the Society wishes that the government had gone further in its initiatives, one for example in moving from a system of taxation to system of charging as a way of funding the road network at a national level. The other in extending local authorities proposed powers to levy charges for non-residential parking to include out-of-town shopping centres. Both of these are potentially significant tools to encourage landowners and occupants to reconsider the use of sites and developments which do not assist the achievement of integrated sustainable development,s and also in encouraging the adoption of green travel plans.

  7. The Commission for Integrated Transport is welcomed as a forum for resolving the difficulties which might stand in the way of some of the hard decisions which remain. It needs to be briefed to advise on the practicality and timescales of taking some of these hard decisions. It should provide a continuing public voice for integrated transport, keeping matters on the political agenda and not just be a back-room think tank.

INSTITUTIONAL ARRANGEMENTS

  8. The relationship to decision making by other bodies which influence transport was not sufficiently spelt out in the White Paper itself and further work needs to be pursued. Much decision making in the transport field is made by private companies and mechanisms need to be developed to secure their co-operation with the initiatives to be taken by public bodies.

  9. The Planning Officers Society accepts that the planning system of itself cannot solve the problems of many decades of misguided transport policies, but it has some concerns that the Society's message has been taken too far in that within the White Paper itself there now appears to be an insufficient explanation of the mechanics of integration of transport with planning and land use. The Planning Officers Society does not wish to claim an ascendancy for planning, but it is the relationship of transport with planning, which now needs to be expounded. Planning is not marginal to decisions being made now about transport changes. It is central to decisions being made now about land use changes, and can make an immediate impact upon securing the objectives of the White Paper even in advance of further legislation.

  10. As is to be expected, the White Paper's strengths lie in setting a direction and establishing principles. Attention now needs to be given to means of implementation, from Regional Planning Guidance right down to Development Control. Delivery is as important as sentiment, and there now needs to be considerable work done. Much of the responsibility appears to fall in the local authority basket, but in many ways, the institutional framework is lacking. There is no such thing as a single "Local Transport Authority" and authorities at differing tiers have overlapping responsibilities. There is a significant task of co-ordination to be tackled.

REGIONAL GUIDANCE

  11. Attention now needs to be paid to the level of transport detail expected to be covered in Regional Planning Guidance. Great store is set by such guidance in the White Paper. The legitimacy and content of regional transport strategies was not spelt out, and development work on this issue needs to be pursued if the current reviews of Regional Planning Guidance are to address this issue effectively. The new PPG11 will be important in setting out clear guidance. The capacity of regional organisations to undertake this work needs to be understood.

LOCAL TRANSPORT PLANS

  12. Local Transport Plans should be a high priority issue to be examined. The Planning Officers Society welcomes the concept of local transport plans, including a transport strategy to reflect the wider context of society's needs such as health, security, the environment and social exclusion. However, it feels that the White Paper has given insufficient emphasis to the relationship between these and other plans—in particular Structure Plans, UDPs and Local Plans, which were hardly mentioned. These relationships are likely to be particularly critical if local authorities are going to succeed in delivering the government's objectives. The Planning Officers Society understands that advice on local transport plans, and a revision to PPG12 giving advice on the relationship between local transport plans and the Development Plan system is in preparation by the DETR. This advice will need to clarify the following points:

—  the primacy of plans prepared at different times and by different authorities;

—  the hierarchy of plans and the extent [and direction] of compliance between them;

—  the spatial extent of local transport plans and the responsible authority. It may be assumed that they would be prepared by local highway authorities correlating to their geographical area, but there could be advantages, particularly in metropolitan areas or other agglomerations for jointly-prepared plans, and in some cases jointly prepared plans engaging parts of several local authority areas. These could build upon inter authority partnerships and joint working established already between counties and districts and across borders;

—  the relationship between the provisions of the Road Traffic Reduction Act in setting targets, especially related to developing environmental indicators and the awaited government sustainability indicators, and what might be included in Local Transport Plans. Our assumption is that the Local Transport Plans will incorporate the expectations of the Road Traffic Reduction Act and this will doubtless be clarified in government guidance.

  13. There needs to be a realistic expectation of the content of Local Transport Plans, especially in detailing proposals relating to land use/transportation policies in Local Plans and their ongoing reviews. LTPs will need to reflect changes in both regional planning guidance and PPGs including the expected revised PPGs 3, 11 and 12. The preparation of LTPs [which will involve transport and planning expertise] will consume considerable staff resources if they are to be effective, and the government needs to resource this adequately.

  14. Clarification is needed about Local Transport Plans becoming statutory "in due course". Statutory status has both positives and negatives. The negative aspects comprise potential bureaucratic delays in allowing for formal objections by interested parties and possibly inquiries into objections. Potential benefits could lie in the concept of requiring decisions by other transport agencies and authorities to comply with the plan. In moving towards a statutory concept, the benefits need to be maximised and the disadvantages minimised.

PLANNING POLICY CHANGES

  15. The Planning Officers Society supports the emphasis given in the White Paper on accessibility to jobs, leisure and services by foot, bicycle and public transport, and the proposal that Development Plans should give better protection to those sites and routes which would be critical in developing infrastructure to widen transport choices. However, in some cases, it is unclear how the new policies will feed into the day-to-day Development Control process, and guidance will be needed to ensure that this happens. Urgent publication of a revised PPG13 is sought, together with appropriate revisions to other PPGs.

  16. Planning policy changes—as distinct from day to day development control decisions, have a relatively long lead time. There is therefore a need to get to grips with what planning needs to do sooner rather than later and because the current situation with the creation and review/updating of development [and particularly local because there are more of them] plans is mixed there will be a percentage that are at crucial stage now if there is to be a significant shift in policy direction or, more realistically, emphasis and detail. Examples are the Northamptonshire Structure Plan [draft stage] and the Warwickshire Structure Plan [deposit draft this Autumn].

CAR PARKING STRATEGIES

  17. Car parking strategies to reduce excess provision will be no more easily achieved as a result of the White Paper. There remains great difficulty in securing a level playing field on parking charges across the regional level. The role of the regional organisations in establishing a level playing field is crucial. The timescales and mechanisms for Private Non-Residential Parking charges and road user charging need to be defined swiftly and there needs to be clarification of the arrangements for the local use of revenue raised, with parliamentary time given to the necessary changes in legislation. There is a surprising acceptance of and commitment to the principles of integrated transport which will easily be lost if the necessary legislation is delayed. Furthermore, it is regretted that the opportunity of getting to grips with parking charges/taxation of spaces at out-of-centre sites, in order to redevelop surplus parking spaces, has been missed.

  18. On the other hand, it might be wrong to assume that the welfare of town centres depended on accessibility by car. Mention can be made of surveys showing over 60 per cent arriving by bus—although the spending power of this group vis-a-vis that of car owners may be another matter.

RESOURCE ENHANCEMENT

  19. The legislation for new forms of charging would be permissive, so money to improve public transport was not assured. Moreover, there appears to be no penalty for those authorities who did not implement the new emphasis. There needs to be greater incentives for local authorities to adopt and carry through the government's new policies.

Chair

Integrated Land Use and Transport Topic Group

24 September 1998