RTPI response to DfT consultation on the amended National Policy Statement for Ports

This is the RTPI’s response to the Department for Transport’s consultation on proposed amendments to the existing national policy statement for ports (NPSP). This consultation sought views on changes to the existing NPSP that were made to reflect significant policy and economic changes since it was designated in 2012.

About the RTPI

The RTPI champions the power of planning in creating prosperous places and vibrant communities. As a learned society, we use our expertise and research to bring evidence and thought leadership to shape planning policies and thinking. As a professional body, we have over 27,000 members across all sectors, and are responsible for setting formal standards for planning practice and education.

Port freight demand forecasts

Q1. What is your overall view of the central case forecasts for unit-load traffic summarised in the draft amended NPSP?

No comment.

Q2. What is your overall view of the central case forecasts for bulk traffic summarised in the draft amended NPSP?

No comment.

Q3. Do you agree that the forecasts should be at national level, rather than disaggregated to regional or even individual port level?

No, work should be done to disaggregate forecasts to a regional, sub-regional, and, where possible, local level. This would better enable strategic authorities to plan for freight and logistics need, and for need relating to other industries that would benefit from proximity to a port. In addition, disaggregated forecasts would be an ideal metric to feed into the planned national infrastructure spatial tool, helping strengthen the evidence base for investment in local ports. See also response to question 5.

Q4. We have forecast higher and lower scenarios for traffic rather than statistical confidence intervals. Do you agree in this case, that this is the appropriate way to depict the inevitable uncertainty in any such forecasting?

There is a risk that non-experts will take the lower and higher scenarios as equivalent to confidence intervals despite this not being their purpose, so this should be clearly indicated. That said, it would be useful to include confidence intervals for the low/high forecasts as well, perhaps in data tables, if not in graphs.

Need for development

Q5. Do you agree that the need for development in the ports sector should continue to be market driven and that decision-makers should accept proposers’ perception of demand and hence need other than in exceptional circumstances?

To an extent, yes. It is reasonable to expect that port developers will go where there is demand. However, it would be useful to have a mechanism for the government to indicate that they would look favourably on port development in a certain area in line with, for example, the growth sectors identified in the industrial strategy. This could include adding specific ports to the national infrastructure pipeline website (if this is not already planned) or, at a strategic level, their inclusion in Mayoral Strategic Authorities’ local growth plans, thus feeding into relevant local plans within the authority. See also response to question 3.

Economic, social and environmental impacts

Q6. To what extent do you think the draft revised NPSP as a whole provides suitable guidance to decision-makers to help them make decisions about development consent applications for new port applications?

The NPSP provides thorough guidance, with a balance struck between the need to provide capacity for the ports sector in line with growth ambitions, and other considerations, such as environment, security, traffic and nuisance.

Q7. Do you think the draft revised NPSP provides suitable guidance to decision-makers on the need to promote equal access to the jobs, services and social networks created by port infrastructure?

No comment.

Q8. Do you think the draft revised NPSP considers all of the significant potential impacts of port development? If not, what do you think is missing and why?

The revised NPSP does identify and consider an exhaustive list of potential significant impacts, we have nothing to add.

Q9. Do you think the draft revised NPSP provides suitable guidance to decision-makers on the impacts of port infrastructure on the local population?

Yes.

Q10. Do you think the draft revised NPSP gives appropriate guidance to decision-makers about when and how they should consider alternatives when it comes to particular projects?

Yes.

Q11. Do you think the draft revised NPSP provides suitable guidance to decision-makers on the impacts of port infrastructure on the natural environment and biodiversity?

Yes.

Q12. Thinking about dredging specifically, do you think that the draft revised NPSP provides suitable guidance on environmental safeguards for capital dredging and requirements for maintenance dredging after a project is implemented?

No comment.

Q13. Do you think the draft revised NPSP provides suitable guidance to decision-makers on the impacts of port infrastructure on the historic environment?

No comment.

Q14. Do you think the draft revised NPSP gives appropriate guidance on how the cumulative and in-combination/synergistic impacts of port development should be considered by decision-makers?

No comment.

Q15. It is a requirement of the Planning Act that a NPS must give reasons for the policy set out in the statement. Do you think the draft revised NPSP fulfils this requirement?

Yes.

Q16. It is a requirement of the Planning Act that the Secretary of State must have regard to the desirability of achieving good design. Do you think that the draft revised NPSP fulfils this requirement?

Yes, it achieves it both functionally (in terms of efficient layout, climate impact, minimisation of nuisance) and aesthetically (limiting any negative visual impact on surroundings).

Q17. Thinking about guidance in the NPS on environmental regulations and mitigation in the round, and drawing on past experience with such regulations and guidance, do you broadly consider it clear, apt to change during the process of an application or proportionate to the problems it seeks to address?

No comment.

Appraisal of sustainability

Q18. To what extent do you think the methodology used to assess the sustainability of the draft revised NPSP is appropriate?

No comment.

Q19. Has the baseline analysis in the AoS missed or misrepresented any environmental, social or economic data?

No comment.

Q20. Are there any additional key sustainability issues relevant to the NPSP that need to be considered in the AoS?

No comment.

Q21. Are the AoS objectives and sub-objectives as set out in the AoS framework appropriate?

No comment.

Q22. Are there any incompatibilities between the main NPSP objectives and the AoS objectives which have not been identified in the AoS?

No comment.

Q23. To what extent do you think the alternatives covered are appropriate? Are there any additional alternatives that should be included?

No comment.

Q24. To what extent do you think the approach taken in the AoS to the assessment of alternatives is suitable?

No comment.

Q25. Do you agree with the results of the assessment of alternatives?

No comment.

Q26. To what extent do you think the assessment correctly identifies the sustainability effects of the draft NPS?

No comment.

Q27. Have any key findings from the AoS report not been taken account of properly in the NPS?

No comment.

Q28. To what extent do you think the approach to monitoring is sufficient to monitor the sustainability effects of the NPS?

No comment.

Q29. To what extent do you think the appropriate assessment is a suitable high-level assessment of the impact of port development on protected sites and species?

No comment.

Q30. Do you agree with the analysis of costs and benefits set out in the impact assessment?

No comment.

Q31. Are there any impacts of producing a national policy statement that have not been considered?

Despite being an NPS for a key strategic industry that underpins other strategic industries, there was little consideration in the NPSP for how the guidance will intersect with spatial development strategies, and other strategies with a spatial element such as the industrial and infrastructure strategies. Though we agree that port development is largely market-driven, there is an opportunity here for the government to proactively encourage development of the port sector and those sectors it serves. Disaggregation of port forecasts would enable their use in strategic planning and therefore better direct investment in ports. More broadly, providing guidance in the NPS requiring planners to have regard for Spatial Development Strategies, forthcoming national spatial priorities, and place-based business cases would ensure that local and national growth priorities are appropriately weighed in decisions on planning applications for ports.

Q32.To what extent do you think the ‘habitats regulations assessment’ is a suitable or unsuitable high-level assessment of the impact of port development on protected sites and species and why?

No comment.