CIHT Responds to Department for Levelling Up, Housing and Communities NPPF Consultation

2nd Mar 2023

CIHT has responded to the Department for Levelling Up, Housing and Communities consultation on reforms to national planning policy.

Get ahead with CIHT Membership

Join other savvy professionals just like you at CIHT.  We are  committed to fulfilling your professional development needs throughout your career

Find out more

The Chartered Institution of Highways and Transportation (CIHT) welcomes the opportunity to respond to the “Levelling-up and Regeneration Bill: reforms to national planning policy” consultation. CIHT has called for planning system reform for some time to properly integrate land-use  and transport planning, most recently in the whitepaper ‘Fixing a failing planning and transport system’. This collaborative research included views from over 700 CIHT, RTPI and TPS members with over 3,500 written responses on to how to fix the critical inter-relationship of land-use and transport planning.

The proposed immediate changes to the National Planning Policy Framework in this consultation give focus to the reforming of housing delivery, with opportunity for further change indicated through National Development Management Policies (NDMPs) as outlined in the consultation’s questions.

CIHT’s immediate and pressing observation is that this consultation fails to immediately address the critical inter-relationship of planning and transport. On this basis the proposed changes to the planning system as currently set out represent a missed opportunity to make a greater contribution to transport decarbonisation and the car-dependent nature of too many developments. 

As such, CIHT would like to reinforce the following points: 

  • The scale of the challenge is considerable: over 90% of members surveyed from CIHT/RTPI/TPS agreed that the relationship between planning and transport in achieving net zero is important [1];
  • an RTPI recent study has shown that most areas of England will struggle to reduce transport emissions at the scale and pace required even if all new development is car-free, strict traffic removal policies are in place, and the shift to electric vehicles and grid decarbonisation proceeds at speed [2];
  • leaving some key changes to the next further review of the NPPF – which could be in 2023, 2024 or 2025 depending on elections and political uncertainty - is too late. There is an urgent need to change delivery on the ground more rapidly.

The correct integration of both planning and transport can play a leading role in tackling the climate emergency, as well as supporting policy drivers including levelling up and improvements to health. A new strategic NPPF is crucial for this challenge; the current consultation should have provided the opportunity for radical change.

In addition to an individual response, CIHT has played a key role in the delivery of a collaborative response to this consultation with the Transport Planning Society (TPS), Sustrans, Transport for New Homes (TfNH), Living Streets and CPRE the countryside charity. This joint effort underscores the importance of the key recommendations we have made.

To view CIHT’s response, click here.

To view the collaborative response between CIHT, TPS, Sustrans, TfNH, Living Streets and CPRE, click here.

Key recommendations

The style and role of the NPPF

To ensure the Governments objectives on net zero, transport decarbonisation, levelling up and housing delivery are met, we must see an integrated land-use planning and transport planning system. This would support the delivery of sustainable transport infrastructure that enables modal shift to active travel (walking, wheeling and cycling) and public transport.

The new NPPF should focus on the clear strategic objectives and policies required to be implemented across the country to deliver the above agenda at the pace required. It will need a more directional style especially in the context of location, transport, and the form of transport to be provided. It should be ambitious but enable delivery.

Therefore, the revised NPPF should have clear linkages to (yet to be released) Manual for Streets[3]; Local Transport Plan guidance; Gear Change; LTN 1/20; Connectivity Tool (under development by DfT); and Quantifiable Carbon Reduction guidance (yet to be released by DfT). This integration will be key to demonstrate robust and integrated policy that shows a firm commitment to tackling climate change, something that CIHT has advocated from in the advice, ‘Better planning, better transport, better  ’.

CIHT would also like to see paragraph 113 (111 current version) of the NPPF changed to reflect the need for carbon reduction, something that the current wording of this paragraph undermines in that only “severe” impacts are accepted as criteria for refusal of planning permission. [4] This change is something that CIHT has repeatedly called for, most recently in ‘Fixing a failing planning and transport system’. [5]

Location and Accessibility

Creating quality places for people and reducing carbon requires the co-location of people with key services so the NPPF should include requirements that drive this process through the Local Plan and Local Transport Plan.

By co-locating developments with services and making them accessible by sustainable transport we can promote local-living, and in turn, tackle the climate crisis, level up our communities and deliver “well-designed beautiful places to boost civic pride.”, as championed in this consultation.[6] [7]

To deliver this, we need to see a shift towards accessibility assessment for developments in place of current Transport Assessments. [8] [9]

Strengthened Requirement for Sustainable Transport

The current NPPF is too weak on requiring sustainable transport provision.  Chapter 9 is entitled ‘Promoting Sustainable Transport’, which is inadequate. The NPPF only requires ‘opportunities’ to be taken and uses the phrase ‘so far as is possible’. An applicant therefore only has to show there are no realistic opportunities for walking, cycling or public transport connectivity to satisfy the NPPF.

It is not sufficient to merely ‘encourage’ active travel and public transport (Paras 92 c; 112 a).  Active travel and public transport must be enabled by new developments – for example by providing on and off-site cycle facilities that are compliant with Local Transport Note 1/20. This will be critical for achieving 50% of all journeys in towns and cities to be walked and cycled by 2030 as outlined in the Transport Decarbonisation Plan [10].

In addition, the current definition of sustainable transport in the NPPF is too open to interpretation. Zero, and ultra-low emission vehicles promote car use, and as such, induce demand on the road networks. This is not sustainable. Sustainable transport should therefore be defined as Active Travel and Public Transport.

CIHT would encourage the revised NPPF to signpost to CIHT’s ‘Buses in Urban Developments’.  This would be beneficial as Buses in Urban Developments provides further information on how bus provision can be effectively accommodated into developments. [11]

Embed nature-based solutions

We need Green and Blue Infrastructure (GBI) to create better streets and roads; at the same time roads serve an important role in creating green linkages and reversing biodiversity fragmentation.  As stated in the CIHT publication, ‘Green and Blue Infrastructure: A Transport Sector Perspective’, we believe the many benefits that GBI can bring to an area are overlooked. This stems from a lack of planning, integrating and maintenance of GBI features that leads to them being seen as a ‘decorative add on’ rather than a way of creating beautiful, biodiverse, climate resilient places.

For the planning system to truly deliver “well-designed beautiful places”, the CIHT recommends that more is done to establish an end-to-end process for including GBI in projects on our streets/roads/highways.

The way to do this is for the NPPF to consider the important role that GBI can play in making sure that beautiful and well-designed sustainable development is delivered that can tackle climate change. It must also include a key emphasis on maintenance of GBI within planning policies. Our research has shown that the costly nature of maintenance is often seen as one of the biggest disadvantages to including GBI in projects[12].

If the NPPF states that maintenance of GBI should be a key consideration of planning policies, and provides guidance on how to do this effectively, this will help demonstrate that GBI is neither too difficult nor expensive to maintain.

Skills and experience

The key recommendations outlined here clearly demonstrate climate action at the heart of them, but these cannot be delivered without well-skilled, and experienced professionals working in our sector. Worryingly, a recent CIHT future skills survey highlighted that 14.9% of respondents thought decarbonisation targets were simply not achievable.  As a professional institution, one of CIHT’s objectives is to promote learning. This means providing the skills, training and qualifications to be the workforce that our society, the environment and the economy need. To make sure of this, CIHT has recently launched A Transport Decarbonisation Pathway that provides our members with a structured framework to fulfilling climate action related Continuing Professional Development (CPD) goals.

Want to find out more?

To find out more about CIHT’s commitment to sustainable development, listen to Neil Johnstone, CIHT President in conversation with Kyle Fairbairn, CIHT Policy Advisor, on our latest episode of Transport Talks.

Check out our whitepaper, Fixing a Failing Planning and Transport System, detailing the key actions from over 700 professionals at CIHT, RTPI and TPS.

[1] Fixing a failing planning and transport system, p.5, CIHT, (2022)

[2] NET ZERO TRANSPORT: The role of spatial planning and place-based solutions, RTPI, (2021)

[3] CIHT members have previously indicated a strong desire for strengthening Manual for Streets position (76% of respondents said MfS should be mandatory)

[4] National Planning Policy Framework (NPPF), (p. 32, 2021)

[5] Fixing a failing planning and transport system, p.5, CIHT, (2022)

[6] Levelling-up and Regeneration Bill: reforms to national planning policy, DLUHC, (2022)

[7] CIHT Response to Planning for the Future: White Paper 2020, (2020)

[8] In CIHT, RTPI and TPS survey, 58% of respondents indicated that they faced issues with TA guidance in creating sustainable development.

[9] The Department for Transport is currently developing a connectivity tool, expected to be launched in 2023.

[10] Decarbonising Transport: A Better, Greener Britain, DfT, (2021)


[12] Green and Blue Infrastructure: A Transport Sector Perspective, CIHT, (2023)

>>> Read CIHT's response here


Want to find out more? Read our whitepaper, Fixing a Failing Planning and Transport System, detailing the key actions from over 700 professionals at CIHT, RTPI and TPS.

Comments on this site are moderated. Please allow up to 24 hours for your comment to be published on this site. Thank you for adding your comment.

{{item.AuthorName}} {{item.AuthorName}} says on {{item.DateFormattedString}}:


Get ahead with CIHT Membership

Join other savvy professionals just like you at CIHT.  We are  committed to fulfilling your professional development needs throughout your career

Find out more

Sign up to the APM Newsletter.