Chapter 15
150) Do you agree that policy TR1 will provide an effective basis for taking a vision-led approach and supporting sustainable transport through plan-making? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI welcomes the provisions in TR1, including reference to the Connectivity Tool and continuation of a vision-led approach to planning for transport. TR1(1)(a) contains a commendable amount of detail around encouraging joined up and early engagement in local plan preparation and identifies the key sectoral plans of relevance. The RTPI would welcome such an approach across infrastructure types. However, it is not clear from the wording whether this is in relation to local plans or the development plan. As set out in response to Q14(a), we believe the approach set out in TR1 needs to be better embedded and prioritised throughout the Framework. In particular, in relation to the preparation of the development plan. Therefore, the RTPI would wish to see fuller connection and reciprocity with Chapters 2 and 12, S1, S2, and CC1, noting only HO4 makes explicit reference to TR1. As previously set out elsewhere in our response, we would also wish to see a better connection with the train station policies proposed in the Framework and plan preparation.
We notice in TR1(2) the departure from the use of language relating to the development plan. We are unclear over whether this is to specifically prohibit Neighbourhood Plans engaging with this policy or it is inconsistent with the approach to nomenclature taken throughout the proposed Framework. The RTPI would welcome further guidance on what constitutes a significant amount of movement arising from new development. We would also query whether SDSs would be able to undertake such assessments given that their role would be predominantly to identify broad areas of growth.
151) Do you agree that policy TR2 strikes an appropriate balance between supporting maximum parking standards where they can deliver planning benefits, and requiring a degree of flexibility and consideration of business requirements in setting those standards? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
To provide a more balanced approach to transport parking standards, the RTPI would welcome the inclusion of reference to facilities necessary to support active travel being considered within this policy, such as minimum cycle storage standards. This would support a better alignment of TR2 with TR4(1)(b).
152) Do you agree with the changes proposed in policy TR3(1a), including the reference to proposals which could generate a significant amount of movement, and the proposed use of the Connectivity Tool? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
We note that the TR3 references vision for the site, but we are unclear how the vision led approach to transport planning set out in TR1 flows into decision making. As set out in response to Q150(a), we would welcome guidance on what is considered a ‘significant amount of movement’, such detail would be usefully included in the associated PPG given the complexity of understanding factors such as, context and time. As a general comment regarding the national decision-making policies relating to promoting sustainable transport, we note that in no situations has substantial weight been afforded to them. Given the critical role that transport plays in creating well-designed, sustainable, and inclusive places, consideration of affording substantial weighting would be welcomed.
Regarding the Connectivity Tool, the RTPI would wish to understand how it will be updated in terms of understanding increased frequencies or assumed increases in frequencies of movement as a result of change in development patterns over time.
153) Do you agree that proposed policy TR4 provides a sufficient basis for the effective integration of transport considerations in creating well-designed places? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Neither agree nor disagree.
a) Please provide your reasons, particularly if you disagree.
Similarly, as in the response to Q153(a) the RTPI would welcome clarification of how the policy can be applied in a way that regards the vision led approach to transport planning. The RTPI welcomes the new provisions for incorporating facilities that prioritise sustainable transport and the explicit references to meeting the needs of older people, children, and disabled people. Whilst contained within footnote 56, the RTPI would like to see a prominent placing of the reference to the Manual for Streets in the policy itself.
Whilst the RTPI supports the general intention of TR4 in terms of effective integration of transport considerations and creating well designed places, we hold some reservations over the realistic prospect of the practicalities of implementation. For example, regarding TR4(1)(d), it is very difficult to design developments that can meaningfully encourage behaviour changes in the operational nature of the delivery of goods. To further support the implementation of this policy in terms of achieving high quality design outcomes, the RTPI would welcome reference to the need for maintenance to be considered at the earliest possible stage when creating well-designed places.
154) Do you agree with policy TR5 as a basis for supporting the provision and retention of roadside facilities where there is an identified need? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree
No further comment.
155) Do you agree that the amended wording proposed in policy TR6 provides a clearer basis for considering when transport assessments and travel plans will be required, and for considering impacts on the transport network? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) Please provide your reasons, particularly if you disagree.
The RTPI believes that TR6(3) should be reverted back to wording similar to the current NPPF paragraph 116, whereby proposals should be refused if their impacts on the transport network are deemed severe.
156) Do you agree the proposed text in policy TR7 provide an effective basis for assessing proposals for marine ports, airports and general aviation facilities? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) Please provide your reasons, particularly if you disagree.
The RTPI would welcome a more positive framing of the assessment of such proposals, as forms of transport and their contribution to economic development. However, we note the significant amount of movement such sites can create and therefore will require comprehensive and thorough assessments to establish potential impact.
157) Do you agree with the additional policy on maintaining and improving rights of way proposed in policy TR8? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
To support the objectives of this policy in terms of improving rights of way, the RTPI would welcome wording which prevents the introduction of vehicle traffic to the rights of way network.
