IPI Submission on Spatial Planning and National Roads
Thursday, September 30, 2010
Catríona Barrett
Department of Environment, Heritage and Local Government,
Custom House
Dublin 1
27th September 2010
Dear Ms. Barrett
Re: Spatial Planning and National Roads, Consultation Draft
The Irish Planning Institute welcomes the opportunity to comment on the consultation draft document ‘Spatial Planning and National Roads’. This submission makes specific comments on chapters contained in the draft guidelines and includes additional comments on the overall document.
General comments
Focus of document
It is welcomed that the draft guidelines highlight that Government policy no longer proposes to cater for unlimited road traffic growth however recognizes the need to maintain the current road network which has provided better links and driving times to main cities and towns encouraging investment in such areas. The Institute welcomes that the ‘Smarter Travel: A new transport policy for Ireland 2009-2020’ has set the context for this document thus encouraging the move away from promoting unlimited growth in private transport to promoting a more sustainable public transport network. The Irish Government has committed to continue to invest in the overall transportation system in Ireland. Smarter Travel promotes the alignment of spatial and transport planning. This is also the stated aim of the draft Guidelines. Whilst the Institute welcome the introduction of guidelines which will safeguard the existing transportation network, in this instance national roads, it is suggested therefore that the opportunity to issue a more comprehensive and encompassing document that provided guidance on spatial planning and all modes of transport showing an integrated approach as extolled by Smarter Travel should be embraced.
In respect of Smarter Travel the draft Guidelines conclude that:
“It is of critical importance therefore that the considerable investment that has been made to date in our national road network is protected and that premature obsolescence is avoided through careful land-use planning.”
We would suggest that this misses the point of the Smarter Travel Policy.
Smarter Travel is not focused on reducing future expenditure or protecting past investments as the consultation draft in this section and generally throughout seems to be.The most significant aspects of the Smarter Travel policy framework are the assumptions that
(i) In the period to 2020 there will be no increase in the total distance travelled by the national car fleet;
(ii) the total share of car commuting will drop from 65% to 45%; and
(iii) the share of walking cycling and public transport will rise to 55%.
The draft Guidelines, rather than acknowledge the aim to reduce car commuting numbers and stabilize the total mileage driven by the car fleet, seem to assume that traffic will continue to grow.
In its section “Future Design Capacity”, the draft Guidelines carefully describe the NRA’s use of a 15 year design horizon as the basis for volume/capacity design requirements and extols the virtues of that approach. The described benefits make it clear that the assumption is that road proposals will need to be designed to accommodate traffic growth over the 15 year period.
In our experience, the NRA’s approach to Traffic Impact Assessment still assumes that traffic levels will continue to increase based on historic trends and judges a proposal’s impact on that basis rather than take on board the drops in traffic levels suggested by Smarter Travel.
There is also a notable change in the attitude of Government Policy contained within Smarter Travel towards congestion. Measures are focussed more on the use of technology to tackle congestion directly rather than continuously increasing capacity in a way that simply invites more traffic onto the roads. There is a growing realisation in the Policy that it is the persistence of road congestion that will ultimately change commuters’ attitudes.
The broad strategy therefore is, first of all, to ensure that people have a choice of transport modes and then to encourage them to make a modal switch - if necessary by using fiscal measures to discourage car use. The “Draft Planning Guidelines on Spatial Planning and National Roads” do little to reflect this policy. The draft guidelines sign up to the ideas that current road capacity must be protected, lands should be reserved to accommodate future road growth and new road proposals should be designed to withstand 15 years worth of traffic growth. The implication of Smarter Travel however is that rather than delay congestion for 15 years it would be more appropriate to design new road proposals to accommodate no more traffic than there is at present thereby forcing a modal shift. The draft Guidelines would appear to acknowledge the existence of Smarter Travel but ignore its content. Smarter Travel is an ambitious and radical strategy. It demands a new way of thinking whereas the NRA’s approach is firmly rooted in the past. Whilst it may be understandable that a body solely concerned with national roads would focus on such roads alone and would wish its network to ever expand, the Department of the Environment, Heritage and Local Government remit is considerably wider and therefore should be reflected in any such guidelines that are issued.
In Section 3.3 “Traffic and Transport Assessment” the draft Guidelines refer to the 2003 “Traffic Management Guidelines” which outline the approach to Traffic and Transport Assessment as well as the NRA’s “Traffic and Transport Assessment Guidelines”. Planning authorities are advised by the draft Guidelines to be guided by these documents when advising prospective applicants for planning permission of the need for Traffic and Transport Assessments. Box 2.3 “Overall Recommended Content for Development Plans and Local Area Plans (LAPs)” also refers to documents that have to varying extents been outdated by Smarter Travel. These documents however have not been updated to take account of Smarter Travel and the Institute suggests that in order to provide an all encompassing and coherent framework of guidance documents for spatial, transportation and land use planning these documents need to be replaced or updated.
Importance of National and Regional Plans The Institute considers that the role of the National Spatial Strategy and the Regional Planning Guidelines are fundamental to developing an overall spatial planning and transportation framework plan. With specific regard to the road network, the Guidelines should place more emphasis on the need for local authorities to clearly identify national roads including those roads whilst not falling within the category of national roads but may be important regional or local roads that are used as main arteries between motorways and national roads. Specific policies and objectives to ensure protection and prevention of premature obsolescence of these roads should be set out in the relevant regional and local plans. Future land use patterns and subsequent investment in transportation should have regard to the national settlement hierarchy contained in the National Spatial Strategy, thus ensuring a more coherent and balanced approach to development of areas into the future. This also allows for better planning of future public transport networks and for allocating investment priorities in particular areas. Therefore planning authorities should ensure that all county development plans and local area plans are in line with the provisions of the NSS and relevant Regional Planning Guidelines. The importance of reviewing and updating the National Spatial Strategy is also of increased importance.
Further, spatial planning should have a role in determining where interchanges are best located and what the best land uses adjoining these interchanges would be. While it is agreed that planning policies must recognise the need to protect the investment in national road infrastructure, the decisions with regard to the identification of need, and route planning of new national roads, should be based on a ‘corridor management’ approach where a plan-led development approach for strategic national road corridors is taken into account before a route is chosen. Such a corridor study should not only look at the future route and alignment of a motorway, but also at key planning issues such as: (i) the potential contribution of alternative transport modes within the corridor, (ii) the location of potential multi-modal interchanges, (iii) optimal locations for motorway interchanges from a spatial planning rather than just a roads planning perspective, (iv) land use policies for the areas in the vicinity of interchanges (v) identification of potential strategic sites for certain forms of development in the vicinity of new national routes. Such an approach would suggest the need for a two way process between the National Roads Authority and planning authorities, rather than the one way process that is suggested in the draft guidelines. It could also lead to a more ‘creative’ development of our national roads infrastructure instead of being based on predictions of travel demand.
Specific Comments
Chapter 2
With regard to consultation between Planning Authorities and the NRA, the Institute would suggest that the Guidelines set out that where recommendations are made by the NRA to planning authorities as part of the review of development plans that the provisions of the development plans should be broadly in line with such recommendations. Where planning authorities decide not to take the recommendations on board or include and/or provide for policies which conflict with such, the planning authorities should clearly justify on planning and public safety grounds why they have not taken the comments and recommendations on board. However, the Institute would again emphasis that the NRA is charged with responsibility for Motorways and National roads only and that a land use and transportation authority which would provide such recommendations would be more beneficial ensuring more joined up thinking. Further to this it is considered that multi-modal transportation modeling, taking into account private car and public transport modes, can inform the preparation of core strategies and the appropriateness of zoning proposals adjacent to the national road network. This will avoid the situation whereby traffic modeling is only used for the detailed assessment of impacts after lands have been zoned.
The role of State Agencies and others such as private bus operators in the provision of infrastructure has been highlighted in Section 2.3. However the Institute are concerned that undue emphasis is being put on the state agencies to provide such infrastructure in an economic climate where realistically the private operators may have an opportunity to play a more meaningful role in this respect. The Institute would suggest that that a sentence is included where local authorities are encouraged to engage in meaningful consultation with all private bus service operators who are licensed to run services within the relevant functional area by the Department of Transport as there tends to be a bias to consult only with state agencies.
The final paragraph of Section 2.3 regarding the general content of development plans sets out that such plans should be consistent with other guidance contained in the ‘Retail Planning Guidelines (2005) and Sustainable Rural Housing Guidelines for Planning Authorities (2005)’ the Institute suggest that this section should state that development plans should be consistent with all guidance issued under Section 28 of the Planning Act, rather than specifically mentioning particular guidelines.
It is suggested that Box 2.3 should also make reference to County Development Plans encouraging the use of mobility management plans particularly where larger developments are proposed. It is also suggested that this section should contain a statement that policies in development plans should ensure that the national roads network and in particular its strategic junctions should not become the focus for dispersed industrial, commercial or retail development.
The Institute welcomes the shift towards more sustainable transport modes through the use of park and ride facilities which are in close proximity to national transport routes which would allow for the safe operation of public bus services to and from cities, towns and villages. Planning Authorities should during the process of making a county development plan, local area plan ensure that the most appropriate locations for such facilities are identified.
Sections 2.3, 2.4 and 2.5 are confusing. Section 2.4 would appear to lay down the broad principles for governing access to national roads and in particular development in and around junctions. The second set out bullet points on page 21 appear to continue to outline the rationale for facilitating development along the national road network. These should be the exception rather than the norm and therefore placed in Section 2.5.
Section 2.9 The Institute would suggest that a sentence be inserted in this section to ensure that Planning Authorities do not use bye-laws in relation to speed limits on national roads to accommodate development which otherwise would not normally be permitted where the maximum speed limit would generally be expected to be in force.
Section 2.10 The Institute strongly suggests that where new motorways, national roads or high quality dual carriageways are proposed that the location of service areas along such roads should be clearly identified as part of the overall scheme at design stage. Furthermore, development plans should also clearly identify the most appropriate locations for service stations. Where there are existing long stretches of roads and the need for service areas has been identified, planning authorities should ensure that the most appropriate locations are identified during the development plan stage or any review of such plans.
It is also suggested that in the interests of clarity that a definition of ‘on’ and ‘off-line’ services is provided in the guidelines.
Chapter 3
Section 3.5 The Institute would suggest that where a Planning Authority decides to dispense with the requirement for a road safety audit in the case of applications for individual dwelling proposals, it should be clearly set out in relevant planning reports why the proposed access would not compromise existing safety standards of the road in question.
Section 3.7 The display of unauthorized signage in particular the use of parked lorries with large advertising hoardings on bridges over motorways is an increasing problem. The guidelines should emphasize the importance of planning authorities in conjunction with the NRA using powers within the Planning and Development Act to actively address this issue. The importance of taking enforcement action immediately is vital in the interests of public safety and visual amenity. The Institute would also suggest that Planning Authorities should be encouraged to include a policy in their development plans that specifically prohibits the display of signage, other than directional signage, along Motorways, National Primary or National Secondary roads.
Appendix 2 Examples of Integrated Roads and Planning Policy
The Irish Planning Institute would be very concerned at the inclusion of some of the examples of good practice (Appendix 2), which it is suggested satisfies the general rules of Section 2.4. Liffey Valley is a town centre at the edge of the area it is meant to serve and served almost wholly by road and motorway access. Whilst the LAP for Liffey Valley tries to make the best of a bad rezoning decision, it is merely post rationalising it. Furthermore, major retail development has been refused by An Bord Pleanala on a number of occasions on the basis of its location and transport. One cannot overcome the problem of inappropriate location. Whilst the inclusion of best practise examples are welcomed, it is considered that such examples should demonstrate successfully integrated roads and planning policy rather than retrospectively implementing integrated roads and planning policy for areas where past zoning decisions were questionable.
The Institute would welcome the opportunity to meet and discuss the issues outlined should the Department consider necessary to do so.
Yours sincerely
Gordon Daly
President
Irish Planning Institute