In the previous posting we saw how the government’s acceptance of the Sixth Carbon Budget necessitates a major reprioritisation of our transport spending locally. Since declaring a climate emergency in February 2019, can we see evidence of the County Council making radical changes to how transport-related developments are designed and assessed, or is it still “business as usual”?
The County Durham Plan, adopted in the autumn of 2020, allocates sites around the county to meet the need for housing. Two sites on the edge of Durham City were removed from the green belt in order to make the land available for housing. The County Council justified the removal of green belt protection partly on the basis that sites beyond the green belt would be less sustainable. It was argued that building on green belt land adjacent to the city would enable residents to walk, cycle and use public transport for a greater proportion of their journeys.
Bent House Lane housing site
In November 2020 Banks Group, which owns most of the Bent House Lane site, submitted an outline planning application, DM/20/03558/OUT. This seeks to establish broad principles for the layout of the site, including a design code, and addresses access to the site including transport impacts and mitigations.
Bent House Lane site location
The Trust considers there is room for a great deal of improvement in the planning application, and that the application does not satisfy the County Plan policies in its present form. But rather than discuss details such as the landscape aspects, the road access to the site, or the relocation of the bus stops, I want to examine and challenge the assumptions behind the approach to the transport impacts taken by the developer and the Council.
Major planning applications are accompanied by a Transport Assessment (TA). Developers hope that the consultants employed to write the TA will be able to demonstrate that any highways impacts can be accommodated within the existing infrastructure, absolving the developer of any need to pay for improvements. In the case of the Bent House Lane application, seven junctions were assessed and modelled. An estimate of likely commuting destinations was produced, using 2011 census data. (Note that commuting only represents 20% of trips nationally, so this method will be flawed in relation to peak time education trips.) Traffic counts were combined with forecasts from the National Transport Model to estimate the likely flows in 2030, with and without the housing development going ahead. Of the junctions studied, in four cases the additional traffic generated by the development would, by 2030, exceed the capacity of the junction:
For three of these, the mitigation proposed is to convert the junctions to roundabouts, or to add traffic signals or extra lanes to accommodate the growth.
Proposed roundabout at the A181/B1283 junction to the east of the site
At the meeting of the A181 and the Sunderland Road there is no room to enlarge the junction, and instead the developer indicates a willingness to contribute funding towards walking, cycling and public transport improvements along the A181 and Sunderland Road corridors into Durham City, and the assessment refers to routes identified in the Durham City Sustainable Transport Delivery Plan. I have to confess that when helping to prepare the Trust’s responses to the application, I did not spot this offer of investment in sustainable transport in section 8.5 of the Transport Assessment. While detailed plans have been submitted for the remodelling of the other junctions, there are no plans covering walking or cycling improvements on the A181 or Sunderland Road. Perhaps the developer is relying on the Council’s preparation of the Local Cycling and Walking Infrastructure Plan (LCWIP) which is expected to be presented to the cabinet in June?
Map from Durham City Sustainable Transport Delivery Plan with roads requiring walking, cycling and public transport improvements highlighted.
Despite the lack of detail, the TA concludes:
Following the implementation of sustainable transport measures of these types, it is considered that the residual impact of the proposed development on the operation of the highway network will be immaterial.
There is no evidence given to support this view. The application lacks detailed plans, evidence or modelling of the alternatives to motor traffic growth. This sadly reflects the importance assigned to motor traffic flow in contrast to sustainable transport by most developers and local authorities. There is a whole industry built around the problems posed by growth in motor traffic, with specialist software, survey techniques, and design solutions which highways engineers will instinctively reach for. But remember! – the Sixth Carbon Budget requires us to steadily reduce the amount of car traffic year by year by about 3% for the foreseeable future. The National Transport Model, which the applicant draws on for the forecast growth, does not yet reflect this. It is a “predict and provide” model based on laissez-faire transport policies which are not equal to tackling the climate crisis.
The Transport Assessment acknowledges (para. 7.7.4) that “traffic growth forecasts at both a national and a local level have historically tended to significantly overestimate growth”. It also notes that changing patterns of work and employment, hastened by the pandemic, are likely to flatten the peak demand. But in order to come to a “robust” assessment, neither of these uncertainties have been factored in. Still less has the need to actually reduce, in absolute terms, traffic levels.
The result is that the planning application, as currently formulated, envisages large-scale works at two or three road junctions to accommodate traffic growth which the application acknowledges is likely to be overestimated – traffic growth which needs to be reversed to meet our climate commitments. These have been prioritised over unspecified improvements for sustainable transport, the effectiveness of which has not been quantified.
Planning policy and the climate emergency
If the Council is serious about prioritising sustainable transport, as it has claimed in various policy documents, then the planning authority should be requiring a much higher standard of analysis from developers, and the highway authority should take a sustainable-first approach to mitigation of the impacts. The expectation can be set by the Council at the pre-application stage.
Most development proposals have some downsides, and determining whether an application should be approved is a matter of balancing different policies and needs. To do this, planners and planning committees have to judge how much weight to give when an application does not fully comply with a policy by comparison with any benefits that will result. I would argue that in the context of the climate emergency, where we have to make a transition in transport “like none we have attempted before” (to quote Professor Greg Marsden), considerable weight needs to be given to the planning policies which favour sustainable transport.
Many developers quote from National Planning Policy Framework paragraph 109 which states that
Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.
The wording in earlier versions of the NPPF referred to “transport grounds” rather than “highways grounds” and developers and the Council sometimes still use the old wording. The change, however, was deliberate and significant. It signifies that development may be refused on various other transport grounds, such as poor provision for sustainable transport, without there necessarily being severe residual impacts on the road network.
What would a sustainable approach look like?
The initial focus should be on the Transport Assessment and any associated mitigations. Most Transport Assessments follow a common pattern, and a standard aspect to include is an assessment of the accessibility of the site by different modes. In the Bent House Lane application, five pages describe the current walking, cycling and public transport networks around the site, and another five pages access the accessibility of local amenities by these modes. The analysis is often quite superficial: for example, as with many other Durham City applications, the section on cycling is keen to mention National Cycle Network Route 14 with its connections to Darlington via Hartlepool and South Shields via Consett, but is silent on the lack of dedicated provision for realistic local journeys.
By contrast, forty-one pages of the main report cover the highway network and the assessment of the junctions. These are supplemented by another 300 pages of appendices which are entirely devoted to motor traffic surveys and modelling.
A sustainable-first approach would also include a qualitative assessment of the pedestrian and cycle network, and would recognise that existing provision may be sub-standard. This need not be any more onerous than the traffic surveys and modelling. For example, there is a simple junction assessment tool in the new government guidance, Cycle Infrastructure Design LTN 1/20 (p. 178), which could be applied to each junction a cyclist would have to pass through to reach the local amenities, schools and employment sites. Most of the junctions around Bent House Lane would score very badly.
Improvements to the walking and cycling infrastructure could then be proposed. The Department for Transport sponsored Propensity to Cycle Tool would be consulted, demonstrating the potential for 17% of commuter journeys to be cycled, given good-quality routes. Such routes might parallel the main road routes, but there is also the opportunity to give sustainable transport a significant advantage by providing short-cuts. For example, from Bent House Lane the Elvet area and the university campus at Mountjoy could be reached via riverside paths. Liaison with local schools might identify other barriers to sustainable travel noted in their school travel plans.
For public transport a simple table of the service frequencies and destinations would not be sufficient: there needs to be a demonstration that journey times would actually compete with alternative modes. Bus priority measures could then be proposed and funded. There would be evidence of engagement with public transport operators.
Planning applications are determined according to the local County Durham Plan, which itself accords with national planning policy, and the change of administration at County Hall does not change this. But the weight accorded to policies – what is judged important, and where compromise can be accepted – is to some extent a political decision. And it is absolutely the preserve of the Council as highways authority to judge what is acceptable in terms of transport mitigations. The applicant has demonstrated that there are transport impacts which require mitigation, and the new administration could insist that major works to increase motor traffic capacity at junctions should be the last, not the first resort.
By prioritising sustainable transport interventions, not only would a greater proportion of the new residents’ journeys be by sustainable modes, but other people would benefit from the improvements, in turn freeing up capacity on the surrounding road network and reducing the need for motor traffic growth to be accommodated. The aim should be to avoid the need to commit any funding to road “improvements” because these will become frozen assets (or white elephants) if we are successful in reducing demand in response to the climate emergency.
If you are interested in more information on the Bent House Lane application, the Trust submitted an initial response to the planning application in January. Pages 4-6 summarise the transport objections, which are set out in detail on pages 13 to 35. A further response was submitted in March which covers public rights of way, road junctions and bus stops.
It may be a while before the full implications of the change of administration at County Hall become apparent, but what is already clear is the scale of change which is required in transport policy. As reported by the BBC in April the government accepted the advice of the Climate Change Committee, and the targets of the Sixth Carbon Budget, published in December, will become law. We now have a commitment to cut UK emissions 78% by 2035. Emissions from surface transport, which accounted for 22% of total UK emissions in 2019, have remained largely flat since 1990. We now have to cut emissions by between six and ten percent per year every year, and because there is a budget, a limit to the total amount of CO2 which can be emitted if we are to avoid substantial planetary warming, if we start cutting slowly we will quickly fail.
At the Westminster Energy, Environment & Transport Forum policy conference on 30 April the opening talk was given by Professor Greg Marsden of the University of Leeds, Director of DecarboN8, a research group of academics at northern universities including Durham. Durham County Council is listed as one of the project partners. Professor Marsden placed the emissions targets into context. The whole 15 minute talk is worth watching on YouTube. Some matters, such as fuel duty and public transport costs, are beyond the influence of local government, but key points for us to consider locally include:
Moving to electric cars will only provide 36% of the reductions we need up to 2029. A further 30% of the savings are proposed to be found through demand reduction.
We ought to use light electric mobility, not cars, for a lot of journeys.
Putting new developments in car dependent locations will make matters worse.
Local transport spending has halved in the last 20 years.
Professor Marsden said that this has to be a transition like none we have ever attempted before and “if it’s not uncomfortable, then it probably isn’t going far enough or fast enough”.
What does this mean for Durham County Council?
The need for demand reduction of about 3% every year for the next decade means that virtually any proposals that involve accommodating additional motor traffic are counterproductive. Proposals for increasing the number of lanes on the A167 between Neville’s Cross and Sniperley, for example, will not only encourage additional traffic, but the costs will eat into the very limited local transport budgets that we desperately need to spend on enabling people to find alternatives to car travel. No doubt there will be readers of this article who will find their journeys a little quicker if road widening is carried through, but such “improvements” are clearly unsustainable.
To allow those who genuinely need to drive to continue to make their journeys, we need to ensure that the majority of shorter journeys, perhaps as many as 1 in 3 in urban areas, switch to less polluting forms of travel. To do this we have to invest in sustainable transport, not roads. The improvements in public health, air quality, and the quality of our public spaces that will result will benefit us all.
The County Council may hope to obtain some funding towards transport infrastructure, via Section 106 contributions, from the housing developers of the Sniperley and Bent House Lane sites. These sites were released from the green belt on the understanding that they were more sustainable than the alternative of building houses beyond the green belt.
The Council must ensure that these contributions go towards improving walking, cycling and public transport links to the surrounding neighbourhoods and the city centre, so that the proportion of the new residents travelling by car is lower than the current averages.
Making best use of limited resources
With local transport funding at such low levels, every penny that the Council spends has to contribute to a positive change. We cannot afford to spend money on transport projects which do not actively reduce greenhouse gas emissions. The time and money being spent on the Sands Public Inquiry in order to defend appropriation of ancient common land in order to build a car park for councillors, in what is said to be one of the most accessible locations in the county, is a sorry example of the Council’s wrongheadedness.
Officer time is also a vital resource. The County Council has spent most of the last decade preparing and promoting two iterations of the County Plan which were predicated on green belt release for housing yielding funding for the Western and Northern Relief Roads. Each time, at the Examination in Public, the appointed Planning Inspectors accepted the evidence of the City of Durham Trust and other local campaigners and deleted the relief roads from the plans. Highways officers who have habitually looked for solutions to accommodate increased motor traffic must now be redirected to designing schemes for bus and cycle lanes, and improving the streets for pedestrians. If traffic levels are going to reduce, and reduce they must, there will be more scope to reallocate roadspace to sustainable transport. Where there is insufficient space to provide dedicated lanes, the Council should consider restricting access to through traffic or reducing speeds.
High in the Council’s priorities must be the creation of Local Cycling and Walking Infrastructure Plans (LCWIPs) which will help the Council bid for central government funding. Two Trustees took part in the stakeholder event for the Durham City LCWIP in January 2020, but we have not yet seen the resulting plan. It is due to be presented to Cabinet in June along with LCWIPs for Chester-le-Street and Newton Aycliffe. Those for the other main towns must be accelerated.
Durham County Council declared a climate emergency in February 2019. The Sixth Carbon Budget sets out demanding reductions in both emissions and in traffic levels which have to be achieved. As the Trust pointed out in its response to the Parking and Accessibility SPD consultation, “to achieve changes of such magnitude, Durham County Council will need to use every tool available. Most interventions will take time to produce results and we have no time to waste”.
Let us hope that the new administration which emerges from the recent elections has the energy and political will to see through changes which, to use Professor Marsden’s phrasing, may be uncomfortable, but which go both far enough and fast enough.
In further articles we intend to look in more detail at recent planning applications and consultations which illustrate the change in mindset which will be required to meet this challenge.
The goverment is providing councils with emergency active-travel funding to ceate temporary interventions to make walking and cycling possible and safe under social distancing requirements. Durham County Council is carrying out a consultation to identify areas that need attention: Street Space in County Durham. The Trust has submitted their response.