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					        Planning Policy Statement 4: Planning for Sustainable
                      Economic Development

    A consultation submission from CTC, the national cyclists’ organisation


1    CTC, the national cyclists‟ organisation, was founded in 1878. CTC has
     70,000 members and supporters, provides a range of information and legal
     services to cyclists, organises cycling events, and represents the interests of
     cyclists and cycling on issues of public policy.

2    Cycling, like other sustainable transport, can provide an alternative to short
     car trips and can substitute for longer car trips where services, employment,
     health and educational facilities are close to where their users live. Providing
     such alternative to car travel and reducing the overall need to travel
     contribute greatly to the abatement of climate change and the prevention of
     obesity, both of which are increasing priorities for government and local

3    We note that some attention has been made to ensure that “safe cycle
     parking” is provided at developments and that sustainable travel choices be
     promoted “wherever possible”. However, we feel more could be done to
     emphasise the economic benefits from reducing unnecessary car travel
     through sustainable local planning strategies. Reduced car travel can bring
     considerable economic benefits to local communities and commercial areas.

4    We are greatly concerned by the proposal to cancel paragraphs 53, 54 and
     Annex D of Planning Policy Guidance 13. Stringent maximum parking
     standards are one of the chief policy levers for ensuring that car-based
     transport is minimised in future commercial developments.

5    The proposed document increases flexibility on use of land for commercial
     developments. The Department, on the bidding of the Barker Review, is in
     danger of sacrificing sustainability for short-term economic gain.

6    We believe that tighter controls on commercial developments are required,
     maximising sustainable transport modes, to ensure that the commercial built
     environment helps meet the twin crises of obesity and climate change.

Sustainable development vs Sustainable Economic Development

CTC – the UK‟s national cyclists‟ organisation                                     1
7   CTC sees no reason for PPS4 to exist when by all recognised definitions
    „sustainable development‟ includes economic sustainability in addition to
    social and environmental, and PPS1: Delivering Sustainable Development –
    which covers all three pillars of the sustainability definition – was published 3
    years ago. Sustainable economic development is directly discussed in
    paragraph 23 of that document.1 Furthermore, there are elements in the
    proposed PPS4 that run in direct contradiction to some of the principles of
    PPS1 and its supplement on Climate Change.

8   For instance, paragraph 9 of the supplement to PPS1 states that regional
    spatial strategies should be prepared to:

        “deliver patterns of urban growth and sustainable rural developments that
        help secure the fullest possible use of sustainable transport for moving
        freight, public transport, cycling and walking; and, which overall, reduce
        the need to travel, especially by car.”2

9   Indeed, the draft document acknowledges that “the planning system needs to
    deliver economic development in a way which is sensitive to the challenges
    of climate change” and which are set out in the supplement to PPS1.

10 The document also paves the way for making local planning more flexible,
   especially by reducing single use or other restrictions on land allocations.
   Increasing flexibility on land use will undoubtedly lead to further expansion of
   commercial areas onto the outskirts of towns, requiring longer trips (mostly by
   car) for those services to be accessed.

Increase in car use is not linked to economic success

11 Growth need not be assumed to be linked automatically with increasing car
   use. An example can be seen from London, where there has been a 1%
   increase in traffic on major roads over the decade to 2006, against a UK
   average of a 15.1% growth.3 Over the same period London has seen the
   highest increase in Gross Value Added per head of all the UK regions – 5.4%
   increase against a 0% average in England.4

  Office for the Deputy Prime Minister, Planning Policy Statement 1: Delivering Sustainable Development.
2005. ODPM.
  Department for Communities and Local Government, Planning Policy Statement: Planning and Climate
Change, Supplement to Planning Policy Statement 1. 2007. DCLG.
  Department for Transport, Transport Trends: 2007. 2006. DfT. Table 4.3
  Office for National Statistics. NUTS1 – Regional Accounts. 2007

CTC – the UK‟s national cyclists‟ organisation                                                         2
12 Although other policy levers have been pulled in London – increased
   investment in public transport, promotion of sustainable alternatives – the
   very modest increase in traffic (a slight fall in central London) has been
   achieved partly through stasis in quantity of parking provision.

13 The role of congestion charging in reducing the level of traffic in Central
   London is often overstated. Figure 1 shows that the overall number and
   modal share of cars entering Central London in the morning peak has been
   falling since at least 1996. In fact the introduction of the congestion charge in
   2003 coincided with a plateau in the overall fall of car use.

                     Fig. 1. People entering Central London during the morning peak, 7-10 am, 1996-2006










                     1996     1997    1998         1999   2000   2001   2002     2003    2004     2005    2006

                            Bus      Private car

Source: DfT Transport Trends 2007

Car-dependence: threats to health and climate change

14 Our fear, shared by many others, is that the proposed cancellation of the
   parking maxima figures for commercial spaces in PPG13 will, coupled with
   relaxing land use standards, lead to an increase in out-of-town developments
   accessed primarily by car.

15 The importance of setting maximum car parking standards for reducing the
   need to travel has been emphasised in the recent Department for Transport
   discussion document, Towards a Sustainable Transport System (TaSTS),

CTC – the UK‟s national cyclists‟ organisation                                                                   3
    paragraph 3.15. The document makes clear the Department‟s continued
    support for the PPG13 maximum parking standard and states that “reducing
    people‟s need to travel will be important to both the climate change and
    equality-of-opportunity goals.”5

16 Relaxing planning and parking standards to allow out-of-town car-dependent
   developments will make it harder for urban local authorities to introduce road
   user charging or other forms of traffic restraint. It is likely that urban retailers
   and other will invariably – with justification – complain of disadvantage since
   restraint measures in congested urban areas would result in more people
   opting to make longer car trips to out-of-town destinations. This substitution
   of longer trips for shorter trips runs directly contrary to the principles
   established in PPS1, PPG13 and TaSTS.

17 The Foresight report on obesity, published in 2007, points out that the
   prevalence of obesity has doubled in the last 25 years, with a quarter of
   adults and 10% of children now classified as obese. Current trends indicate
   that 60% of the population may be obese by 2050, costing £49.9 billion per

18 One of the reasons for this change in people‟s obesity identified by the report
   is our car dependent lifestyles. The report specifically recommends
   “increasing the cyclability and walkability of the built environment” as one of
   the key solutions to preventing an „obesogenic‟ future.6

19 Figure 2 suggests an inverse relationship between cycle use and obesity
   levels across several European countries. In Britain cycle use is low at 76 km
   per person per year and obesity is the highest in Europe at 23%. By contrast
   Danes cycle 936 km a year – 12 times more than people in Britain – and just
   9.5% of the population are obese.

 Department for Transport. Towards a Sustainable Transport System. October, 2007. p. 50
 Government Office for Science. Foresight Tackling Obesities: Future Choices Project. October, 2007. p

CTC – the UK‟s national cyclists‟ organisation                                                           4
                                         Figure 2. Obesity and cycle use in Europe
                             1000                                                                                                     24

                                        23                                                                                            22
    km per person per year

                                                                                                                                           Obesity, % of population


                             500                                                                                                      16

                                                                   12.9         12.8           12.7

                             100                                                                                                9.5

                               0                                                                          s                           8












                                         Km cycled per person per year      % of the population obese

Source: OECD, EU Energy and Transport Figures, 2003

20 The growth in car travel, prompted by the increasing extra-urban commercial
   development, has contributed to the huge growth in greenhouse gas
   emissions from the transport sector – the only major sector of the UK
   economy which shows an increase in emissions. Road transport has
   increased from 8.8% of all UK‟s emissions in 1970 to 21.7% in 2006.7

21 If tackling climate change is to be taken seriously, as the indications from the
   Government over the Climate Change Bill seem to suggest, improving the
   planning of communities to reduce trip distance and increase sustainable
   modes of travel will be fundamental to our long-term success.

CTC, the national cyclists‟ organisation
March 2008

    Department for Environment Food and Rural Affairs, e-Digest of Statistics. 2007

CTC – the UK‟s national cyclists‟ organisation                                                                                                                        5

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