Comments submitted by/on behalf of:

Agent (if appropriate)

Name: Peter Mann

Name: NONE

Organisation: Oxfordshire County Council

Organisation:

Address: Speedwell House, Speedwell

Address:

Street, Oxford

Post code: OX1 1NE

Post code:

Email: peter.mann@oxfordshire.gov.uk

Email:

Telephone: 01865815479

Telephone:

Fax:

Fax:

Policy/Page No

Comments

General

Policy T12

Policy T13

Policy T14

The current version of the RTS is clearer and easier to read and comprehend as the policies and the supporting statements have been separated into two documents. Many of the areas which caused confusion and concern in the earlier version, have been clarified. Virtually all the policies and approaches highlighted within the document are in line with current policies an0d proposals in the Structure Plan and Local Transport Plan. These include support for the promotion of East West Rail and the relocation of Oxford Station. It is particularly pleasing to see that the Oxford Transport Strategy has been singled out as a case study of Best Practice. However, the following issues remain of particular concern.

Charging

Policy T12 states : ‘Local transport authorities should make appropriate use of the powers available under the Transport Act 2000 to introduce new charging initiatives where they consider these are required in order to support delivery of the regional spatial and transport policy frameworks.’

The ability for local authorities to introduce congestion charging was contained in the Transport Act 2000. This included options to apply charges on a single road, a group of roads or area-wide. The LTP contains no proposals for charging and the issue is unlikely to be considered until the next plan period (2006-2011).

Whilst the RTS does now acknowledge that only local traffic authorities have the powers to introduce charging schemes, it seems that the RTS is attempting to impose a regional justification, and even duty on local authorities, to introduce road user charging when the national legislation does not, at present, allow for this. The wording in the policy, however, is confusing, as it seems initially to require local authorities to introduce charging but then gives the discretion to the local authorities to consider the regional justification for it.

The Transport Act states:

"A local charging scheme may only be made if it appears desirable for the purpose of directly or indirectly facilitating the achievement of policies in the charging authority’s local transport plan".

It is now and will undoubtedly remain a requirement for local transport plans to be set in the context of the regional planning and transport frameworks. Any charging scheme pursued by an authority to achieve its LTP policies would therefore, by definition, also acknowledge the regional guidance.

Paradoxically, conclusions from a number of recent Multi Modal Studies, including Orbit, South Coast and Thames Valley, have suggested road user charging that would require cross boundary working to such an extent that a regional, or at least sub-regional, context would be necessary.

The Act does make reference to joint charging schemes and therefore recognises that more than one local authority can make a charging scheme. It says nothing, however, about a regional perspective in justifying a scheme.

As it seems that the RTS is seeking to resolve this failing in national legislation, I would advise responding to the Secretary of State’s consultation by suggesting that the RTS should replace policy T12 with an advocacy policy on charging to ensure that the regional context and justification for it is recognised by a change to national legislation in due course.

Responsibilities for Parking and Planning

Policy T13 states ; ‘Development plans and/or Local Transport Plans should:

1. adopt maximum parking levels of parking provision for non-residential developments, linked to an integrated programme of public transport improvements, that are between 30% and 100% of the maximum level of provision set out in PPG13;
2. include policies and proposals for the management of the total parking stock within transport hubs that are consistent with these limits;
3. apply guidance set out in PPG3 on residential parking standards flexibly, reflecting local circumstances.’

Policy T14 states ; ‘Local transport authorities should ensure that their Local Transport Plans submitted to Government in 2005:

1. identify those major travel generating developments, both existing and proposed, for which travel plans should be developed;
2. require all major travel generating developments to have a travel plan agreed and implemented by 2010;
3. include proposals to trail transport planning advice centres for the transport hubs where they offer the potential to add value.’

Both these policies impose requirements on Development Plans and LTPs that might contradict, or otherwise prove inconsistent with, national guidance, either through PPG12 or the guidance on the next round of LTPs (2006-11). The principle here relates to the relative weight of the RTS, as part of regional guidance, in determining the content of these plans. Policies like these would potentially lead to confusion and conflict, although it is accepted that the RTS can say little without implying some sort of obligation on plans that are also influenced by other guidance. At its most extreme, this may for example disadvantage South East authorities over transport authorities in other regions in their bid to secure Government funding commitments in the 2006-11 period. Clarity should be sought on this issue or alternatively a policy that included wording of a more advocacy nature would be preferable.

Policy T13 rightly recognises that there is a role for local planning authorities, through the application of their (local) development plan policies, in limiting the creation of new private parking stock. However, the development plans themselves will not, at least in a two tier local government structure such as in Oxfordshire, contain the integrated programme of public transport improvements to which the RTS wishes this parking control to be linked. There is therefore an implication that parking control policies in development plans will mesh neatly with

LTP strategies for improving public transport in a given location, when, for various reasons, this may not prove to be the case.

Policy T13 misses the opportunity to recognise the respective roles of district and highway authorities in non-unitary areas in the overall supply and management (including charging) of public and private, on and off-street parking. The relationships here are complex yet critical to effective reduction in traffic congestion

Policy T14 raises difficulties on both the above counts, i.e. the requirements imposed on LTPs outside specific Government guidance and the failure to understand the different roles of local planning and highway authorities in two tier structures. There is also an issue here of legality where it is suggested that major travel generating developments, both existing and proposed, are required to produce and implement travel plans. Such an obligation imposed on existing developments would probably be ultra vires and it would only be through a legitimate and justified planning agreement that such a requirement could be imposed on new development.

-ENDS-