How does the approach encourage use of the ‘outputs’ based
approach identified as the preferred approach
by the DfT publication “Using the Planning
Process to Secure Travel Plans”?
The
'bigger picture' need for the standard is that
it clearly sets the output required for the
travel plan at an early stage in the TA negotiation
process. This will help reduce the commonly
problem of optimism bias of the impact of the
travel plan.
The focus on outputs will
help address the problem of over-promising
and under-delivering. It will concentrate minds
on what is practicable and achievable. It will
help address the common use of optimism bias
to avoid the costs of expensive mitigation
measures or potential refusal of permission.
The
lack of a nationally recognised mechanism through
which outputs can be fairly and transparently
measured, independent from the local authority
or the developer, has up until now been a
the main barrier to the roll out of the preferred ‘outputs’ based
approach.
This procedure refers
to pre-existing operations where a Travel
Plan is to be implemented. We suggest that
this a relatively limited occurrence, as
the imposition of planning obligations to
prepare a Travel Plan would generally arise
only where there is a significant change from
the pattern of the operation such that direct
surveys of the baseline may not be relevant.
It
is likely to be a limited occurrence. For example,
it may be appropriate for expansions of existing
sites where it would be helpful to extrapolate
trends.
The guidance states that the
survey must be commissioned by an appropriate
local authority and be carried out by an approved
independent specialist survey organisation.
Consultants would already be employed by the “developer” who
will have invested knowledge of the site. Surely
they will be best placed to scope the appropriate
surveys and will allow the client to ensure
that he has best value?
It can be difficult
to obtain permissions to visit sites, etc and
in some cases it may be easier to use the existing
consultants. However it is equally important
that the organisation undertaking the survey
is seen to be acting impartially and the risk
of client pressure needs to be ‘managed
out’ as far as possible.
There
is an implication in this requirement that
any incumbent consultancy organisation may
distort the survey design or result to benefit
the developer.
The approach
is intended to ensure that the organisation
undertaking the survey is seen to be acting
impartially and the risk of client pressure
is ‘managed
out’. Consultants acting on behalf
of the developer can find this difficult
and this approach therefore helps to establish
a more transparent approach.
Surely
this is an unnecessary restraint on the developer’s
freedom to employ his chosen advisers?
There
is no restraint on the developer to employ
his chosen specialists to help develop the
transport strategy. The approach simply proposes
that the survey process for proving that
the organisation has met their travel plan
targets has undertaken independently.
Why
isn’t it sufficient to agree with
the local authority the scope of survey and
reporting in relation to any standard data
formatting requirement?
The standardised
approach recognises local authority concerns
that negotiation of survey scope on a site
basis is an inappropriate use of limited local
authority resources. It also leads to a plethora
of different approaches to surveys that make
the data difficult to compare and inform decision
across the county.
In many cases
a developer’s operational
travel and transport patterns will contain
elements which are commercially confidential.
Would they be prepared to share these issues
on a wider basis or to have them under the
control of the local authority where they could
be subject to the Freedom of Information Act?
The
standard approach does not require data of
a commercially sensitive nature. It is monitoring
to assess whether the organisation /developer
has met their targets as detailed in their
TA and travel plan. Copies of these documents
are already available to the public.
The
survey is simply demonstrating that the organisation
has met their travel plan obligations detailed
as part of the s106 agreement. It is in the
public interest to demonstrate that they have
met their obligations and we see no reason
why this information should not be made publicly
available.
It is already possible for
the relevant officers to view information to
confirm compliance with travel plan targets
and there is nothing to stop the local authority
making independent observations, so why the
need for this standard?
The system
makes best use of limited local resources to
confirm compliance with targets using an independent
approach to monitoring. It will reduce ambiguity
in the statistical robustness of the data and
streamline the decision making process.
The
document refers to surveys in the format of
the TRICS® multi modal survey. Surely survey
techniques should be issued which are appropriate
to the situation, rather than a fixed regime?
The
TRICS® multi modal survey has sufficient flexibility
to respond to most survey requirements. The
use of the system as the industry standard
for informing trip rate calculations is already
nationally recognised. The use of the system
as the industry standard for collating monitoring
data will help provide more trip rate information
that will in turn speed up the process of agreeing
appropriate trip rates for sites with effective
travel plans in place.
Will the introduction
of the standard require greater expenditure?
No.
The standard taps into an existing financial
commitment and will not involve significant
additional costs to most.
Developers
already have to collect monitoring information
so the standard does not create a need for
new expenditure. It simply consolidates all
data in one place so that it is more accessible.
Any
consultant of repute will have in place their
own management systems to validate the surveys
to ensure that they meet the required quality
standard. Won’t developers feel
that this represents additional costs?
Local
authorities currently have to assess a wide
variety of surveys from a broad range of consultants.
The local authority has no influence on a
developers’ decision
to assign a ‘consultant of repute’.
Surveys
previously submitted to the local authority
vary widely in quality. The standard approach
will set a de minimus quality
level that is fair and transparent for all
applicants. It is unlikely that the introduction
of this standard will place additional requirements
on so called ‘consultants of repute’ as
they are already likely to meet or exceed
these minimum standards.
The
survey requirements are already part of
the generally accepted cost of development
applications. Using the standardised approach
the costs are more transparent as part of the
development process. This is something which
the greater proportion of developers will appreciate.
Validation
cost is likely to be small. The fact that
it is undertaken by an independent 3 rd party
will help to expedite the planning decision
process. It is hoped that the reduction of
ambiguity in the planning process will minimise
the need for complex technical negotiations
and introduce economies to the benefit of
the applicant compensating for the cost of
the validation.
In our experience,
there is a great deal of information held within
consultancies which will already allow robust
estimates of travel plan impacts to be determined.
The
information held by consultancies is of varying
quality and statistical robustness. Since the
data it is frequently not subject to independent
validation local authorities often express
reservations in accepting the data as the basis
for trip rate calculations and travel plan
targets.
We agree that it should be
the role of the local authority to validate
and agree trip generation estimates and targets
although shouldn’t
this be as part of the overall scoping approval
of the transport assessment?
This will
continue, however the negotiation process should
be less protracted.
In our experience
a regime for monitoring the effectiveness of
the Travel Plan is best built into the planning
approval process or associated legal agreements.
Doesn’t
that give a robust basis for subsequent monitoring?
Most
effective travel plans are secured through
the planning process and associated legal agreements.
However many developers or their occupiers
find the process of ‘signing
off’ the travel plan commitments upon
meeting their targets complex and protracted.
Frequently this is because of ambiguity in
the statistical robustness of the monitoring
survey. We feel that it is therefore important
to set out requirements that will standardise
this process to make it fair and transparent.
The
guidance indicates that the initiatives and
measures should be recorded using the new “Travel
Plan Record Sheet” which forms part of
the TRICS® multi-modal survey. It is not clear
from the documentation whether the record sheet
and survey documentation will be issued to
use free of any copyright restrictions?
TRICS®
have been piloting the travel plan record sheet
on a first round of trial sites. Once these
record sheets have been tested they will be
made available on the TRICS® website for download,
anticipated to be summer 2006.
Will
the ‘after’ survey be a
repeat of the before survey?
This is
mainly the case for local authorities wishing
to use the standard approach of assessing the
impacts of travel plans for a local accreditation
scheme. As explained in the leaflet most travel
plans are secured through the planning process.
They are usually subject to a TA and usually
do not lend themselves to before studies.
Surely
the inherited knowledge of an incumbent consultant
is especially valuable in scoping, implementing
and understanding the after surveys?
The
scope of the travel plan is still agreed during
the planning process. The standard approach
will be used to assess independently whether
the developer /occupier has met the targets
set in their legal obligations.
Why
would we need an independent summary report
to be produced by TRICS®?
This option
is offered in response to local authority requests
for an independent body to assist in resolving
complex disputes.
What is the relationship
between TRICS® and JMP?
JMP are the
current contractors appointed by competitive
tender to manage and market the TRICS® system
on behalf of a consortium of local authorities.
Trics have instructed jmp to develop this facility
in response to requests from members to make
available such a service.
The document
states that the guidance is not compulsory
although local authorities are making it standard
in all planning applications and travel plans.
Have the public and private sectors affected
by the guidance been consulted?
We
have embarked on an extensive programme of
research, development and consultation on the
standard approach to monitoring travel plans
over the past 3 years.
However
all feedback is appreciated and has helps us
to understand the further communication that
will be required to clarify common points
of confusion regarding the standard approach.
How
will this system derive benefits?
The
TA frequently asserts that the Travel Plan
(TP) will be implemented to achieve reduced
trip rates. The standard approach measures
the 'output' of the combined TA /TP.
Government
are concerned that the traffic generated
on the highway network is greater than that
anticipated through approved TA’s.
This is exacerbating congestion on the network.
This
approach will evaluate whether the development
met it trip rate and mode share targets it
alluded to in the original TA. Planning obligations
can then be signed off in the knowledge that
the requirements have been met.
In
measuring the output of the transport strategy
implemented the standard will also collate
useful information about the measures introduced,
which can be used to inform future development
planning decisions.
Will developers
at TA stage be prepared to undertake a TRICS®
quality survey?
We do not
necessarily expect developers to undertake
a TRICS® quality survey at a TA stage as standard.
The only real need for a new TRICS® survey
to be undertaken by a developer prior to
their application is if there is insufficient
data currently available as is currently
the case.
The 'before'
baseline in most cases is generated by the
TA which commonly uses TRICS® to help determine
an appropriate trip rate & mode share.
An
increasing number of S106 agreements require
targets to be met. The standard approach
simply requires that the assessment of whether
targets have been met, is undertaken using
a consistent national standard developed
by TRICS®.
How frequently should
surveys meeting the national standard be
undertaken?
The process is intended to measure the transport impacts of a TA and Travel Plan strategy. At present many authorities only require the assessment survey to be completed once following a period of occupation and travel plan implementation, generally 3 to 5 years after initial occupation. However, it is now becoming the norm for significant development sites to engage in a regular process of assessment (every 3 to 5 years) for perpetuity. This is to ensure that the site transport requirements are continually revisited by the site occupiers and travel demands effectively managed to stay within the footprint originally agreed through the TA.
Why
don’t we use the survey results
collated by the site occupier?
In order
for an organisation to meet their TP targets
it is likely that they will have to undertake
regular monitoring of their own to inform the
development and successful implementation of
their TP. On average these surveys achieve
a 20-40% maximum sample size.
This
causes many arguments about statistical robustness
when organisations attempt to sign off their
S106 requirements with the local authority
and unnecessarily sucks in limited resources
to arbitrate.
The standard
approach will achieve close to 100% of the
sample and therefore be a more accurate assessment
of whether they have met their targets. This
reduces ambiguity and focuses efforts on
meeting the targets rather than arguing about
the appropriate monitoring process.
How
does the local authority collect payment
for the after survey?
To simplify
this process we have suggested that the local
authority collects the money for the monitoring
upfront as part of the S106 agreement.
Otherwise
there may be difficulties in securing payment
at a later stage.
How many travel
plan surveys are likely to be undertaken?
It really depends how quickly the standard approach to assessment is adopted by local authorities across the UK, i.e. planning applications are only approved subject to meeting specific targets for mode share and trip rates that are measured using the standard. In theory, given the present number of relevant planning applications there could be anything up to 3,000 surveys undertaken per year. Initially, in the first few years, it is expected that up to 50 surveys per year will be added to the system and this will build steadily. Replicated throughout the UK and Ireland this will generate a substantial amount of comparable data, invaluable for future planning applications.
Can
the standard be used to keep track of travel
plan implementation across a region?
No.
It is not intended for this purpose.
Local
authorities do need to keep better records
of the development-related travel plans and
keep track of those that have monitoring
requirements. This could be done using a
GIS system or a bespoke system, such as iTRACE
used in London.
Will
TRICS® undertaking counts cause delays
to the local authority receiving
data (as it would normally come direct
to us)?
Not at
all. The standardised approach to assessing
travel plan impacts will actually speed
up the process of receiving data.
It will also ensure the data is robust
and independently validated, before
providing it to the local authority
and the organisation responsible for
delivering the travel plan. The data
collection will be programmed into
a schedule of surveys that is undertaken
by a panel of accredited suppliers.
Dedicated resources will ensure that
data is supplied on time and to a consistent
high quality. The information will
be accompanied by an independent summary
report prepared by TRICS®. This will
speed up not only the process of data
collection but also negotiations between
parties as it will avoid potential
for bias due to vested interest.
Will
there be any scope to do fee deals
if more than one survey needs to
be undertaken (for future monitoring
purposes)?
Yes, it
will be possible to offer a discount
if the survey needs to be repeated,
particularly if the site audit undertaken
to establish the survey requirements
remains valid. Discounts have already
been negotiated with the data collection
companies which means that surveys
commissioned through TRICS® are substantially
cheaper than those commissioned independently
on an ad hoc basis.
Can
the market really stand paying Local
Authority monitoring fee's AND measuring
fee's to TRICS®?
Increasing
numbers of local authorities are now
charging a monitoring fee to pay for
maintaining a database to keep track
of travel plans required. Many do this
in-house as part of their development
control requirements. Most local authorities
promoting the implementation of travel
plans already require an organisation
to pay for a survey to collect data
to demonstrate that they have met their
travel plan targets. The UK Standard
for Assessing Travel Plan Impacts simply
requires this data to be collected
by an independent third party and offers
attractive economies on other alternatives.
Organisations are therefore already
paying for the data and it is not a
new charge. There is general market
acceptance for local authorities to
charge for both in-house systems to
keep track of planning requirements
and the assessment surveys.
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