Travel Planning in Sedgemoor
Consultation Statement
Contents:
1. Early engagement and consultation carried out by Somerset County Council
1.1 Summary of Engagement
1.2 Detail of Key Engagement Events
1.2.1. Sept 2009 half day workshop
1.2.2. Consultation with Developers
1.2.3. Consultation meetings with planning and development control leads at
each LPA
2. Second stage consultation carried out by Sedgemoor District Council
2.1. SDC Executive Committee
2.2. SDC Community Scrutiny Committee
2.3. Public consultation (Regulation 13)
Appendices:
1. Enabling smarter travel through travel planning workshop: Attendees
2. SPD travel plans workshop: summary of discussions
3. Somerset developers’ travel plans draft SPD pre-consultation
4. Developer feedback – travel plans SPD
5. Schedule of Responses
1. Early engagement and consultation carried out by
Somerset County Council
1.1. Summary of Engagement
Dates
15th September 2009
21st October – 30th
November 2009
22nd January 2010
22nd January – 26th
February 2010
10th February – 15th
March 2010
April 2010 – November
2011 (ongoing)
Activity
LPA/LHA half-day
workshop
LPA consultation on 1st
draft (by email)
2nd draft published
online
Developer online
consultation on 2nd
draft
Face-to-face meetings
between each LPA
development control
and forward planning
representatives and
SCC smarter choices
team
Document online on
Moving Somerset
Forward website as
draft technical
guidance prior to
formal adoption
Outcome
Base document drafted by SCC based on
high-level themes discussed/agreed
Responses to consultation used by SCC to
produce 2nd draft
Web link to 2nd draft provided to LPA and
developers for feedback
Responses to consultation (2 developers
replied out of 10 directly contacted) used by
SCC to produce 3rd draft
Issues raised during LPA meetings used by
SCC to produce 3rd draft
Amendments made in light of practical use
and informal feedback to produce 4th and 5th
drafts
1.2. Detail of key engagement events:
1.2.1. Sept 2009 half day workshop:
Workshop with representatives from district council planning and development control
departments and county council highways to discuss the ethos/need for an SPD, potential
content, pertinent issues and thoughts from individual districts and work areas. Files
attached:
 Attendance list (TP workshops attendees 150909)
 Summary of discussions and feedback (SPD Travel Plans Workshop summary of
150909).
1
The feedback from the workshop was used to develop a first draft of the SPD. This was
circulated to attendees on 21st October and email feedback/clarification used to produce a
second draft in Dec 2010.
1.2.2. Consultation with developers – January 2010:
The second draft, developed by SCC in consultation with DC colleagues, was then made
available to developers and consultants for comments between 22nd Jan 2010 and 26th Feb
2010. The draft document was uploaded to the Moving Forward website
(www.movingsomersetforward.co.uk) and made available for any comments over this one
month period. A news feature drawing attention to the consultation was placed on the main
Somerset County Council website and an email sent to planning contacts at each district
council asking them to put it on their own websites and/or notify any regular local developers
or consultant. Ten developers/consultants who had either been particularly interested in the
process or had commented on our travel plan procedures before were particularly invited to
submit responses:










-
Peter Evans Partnership
Canynge Bicknell
Raglan
Bloor Homes
Henry Boot Construction
Abbey Manor Homes
Persimmon
Taylor Wimpey
Summerfield
Strongvox
CG Fry
Two responses were received from Canynge Bicknell and CG Fry. There was some
discussion too with Peter Evans Partnership, though they did not submit a complete
response.
Documents attached:
 Consultation invitation and response form sent to developers/posted on our website
(Developer Travel Plans draft SPD pre-consultation Somerset)
 Summary of responses (Developer feedback travel plans SPD)
The responses from developers were used to formulate a third draft of the SPD.
1.2.3. Consultation meetings with planning and development control leads at each
LPA (Feb/March 2010)
2
Individual meetings were undertaken with each LPA during this period to discuss any further
issues or representations from local areas.
Documents attached:
 Summary of discussions (Notes from DC SPD meetings 4)
Again, this feedback was used to inform the development of the third draft.
A full meeting of representatives from all districts was then held on 19th April and a 4th draft
SPD produced.
As the SPD principles went into operation as SCC guidance on the travel planning process,
further alterations have been made, resulting in the final document that has gone forward for
full consultation through the district councils.
2. Second stage consultation carried out by
Sedgemoor District Council
2.1. SDC Executive Committee
Executive Committee considered the SPD on the 4th April 2012 and approved the draft for
consultation. For the report and minutes please see
https://www.sedgemoor.gov.uk/ramnet/(S(uud0qp55rayn22455s4hxayq))/RamNetDates.asp
x
2.2. SDC Community Scrutiny Committee
Community Scrutiny Committee considered the SPD on the 9th July. For the report and
minutes please see
https://www.sedgemoor.gov.uk/ramnet/(S(uud0qp55rayn22455s4hxayq))/RamNetDates.asp
x
Issues raised:
Issue raised by Scrutiny Committee
Officer response
The quality of existing Travel Plans is poor
One of the purposes of the SPD is to raise
the standard of Travel Plans.
There is a need to ensure that measures set
out in Travel Plans are delivered in a timely
manner
The process set out in the SPD should help
to ensure this.
There is a need to take into account local
needs when developing travel plans
Text has been added to the SPD to increase
its flexibility and to place more emphasis on
pre-application discussion and negotiation
3
between the developer, SDC and SCC as
the Local Highways Authority
2.3. Public consultation (Regulation 13)
The Sedgemoor version of the SPD was published for public consultation on 14th August
2012 for a period of six weeks to 26th September. The document was made available on the
Council’s website in PDF form and a paper copy was available at the Council offices.
Notification of the consultation was sent to all contacts on the Local Development
Framework consultation database with details of how to make comments, and the
consultation was advertised in the LDF newsletter. Formal representations were received
from a total of eight consultees. These are set out, together with officer responses and
proposed changes to the document, in the Schedule of Responses available as Appendix 5
below.
Main issues raised:
Issue
Officer response
The SPD is overly prescriptive and onerous
for developers and risks impacting on the
viability of developments. More account
should be taken of individual circumstances.
Text has been added to the SPD to increase
its flexibility and to place more emphasis on
pre-application discussion and negotiation
between the developer, SDC and SCC as
the Local Highways Authority
There is reference in the document to
national policy documents that are no longer
extant.
References have been removed.
The language of the document is
unnecessarily difficult and inaccessible
Given the technical nature of the document
and its limited interest for the general public,
a complete rewrite is not considered to be a
good use of officer time. However, a nontechnical summary is available on the
website, which is being expanded with the
help of SCC.
4
Appendix 1
ENABLING SMARTER TRAVEL THROUGH TRAVEL PLANNING
WORKSHOP
TUESDAY SEPTEMBER 15th 2009
Attendees
Location: Albemarle Centre, Albemarle Road, Taunton. TA1 1BA
Time: 12pm – 4.45pm (including lunch)
Final List of Attendees:
Name
Organisation
Adrian Noon
SSDC
Andrew Goodchild
WSC
Highways Development Control Team
Arminel Goodall
Somerset County Council
Highways Development Control Team
Carl Brinkman
Somerset County Council
Chris Stone
Somerset County Council
Transport Policy Team
David Mitchell
Somerset County Council
Spatial Planning Team
David Vaughan
Somerset County Council
Accessibility Planning Team
Didier Lebrun*
Somerset County Council
Ed Baker
MDC
Fay Bradley
Accessibility Planning Team
5
Name
Organisation
Somerset County Council
Gary Frecknall*
Somerset County Council
Smarter Choices Team
Hannah Fountain
Somerset County Council
Highways Development Control Team
Helen Vittery
Somerset County Council
Highways Development Control Team
Ian McWilliams*
Somerset County Council
Highways Development Control Team
Jeff Copp
Somerset County Council
Jenny Genge
WSC
Highways Development Control Team
John Gallimore
Somerset County Council
John Meeker
MDC
Transporting Somerset
John Perrett
Somerset County Council
Highways Development Control Team
Jon Fellingham*
Somerset County Council
Julie Moore
TDBC
Planning Control Group
Karen Turvey
Somerset County Council
Les Kimberley
MDC
Mike Ginger*
Highways Agency
Mike O’Dowd-Jones
Strategic Planning Group
Somerset County Council
6
Name
Organisation
Transport Planning Team Leader (Policy)
Nell Cruse
Somerset County Council
Nigel Collins
SSDC
Peter Hughes
WSC
Phil Bissatt
TDBC
Planning Control Group
Phil Higginbottom
Somerset County Council
Principal Planning
Officer (Major
Projects)
SDC
Estates Road Team
Rachel Turner
Somerset County Council
Ralph WillougbyFoster
TDBC
Richard Adams
JMP (Highways Agency)
Transport Policy Team
Richard Sweet
Somerset County Council
Rights of Way
Rob Coate
Somerset County Council
Legal Services
Stephen Moorhouse
Somerset County Council
Transport Policy Team
Stephen Walford
Somerset County Council
*TBC
Last updated 01/09/09
7
Appendix 2.
SPD TRAVEL PLANS WORKSHOP – SCC, LPAS, HA
HELD 15TH SEPTEMBER 2009, ALBEMARLE CENTRE,
TAUNTON
SUMMARY OF DISCUSSIONS
Protocol element 1. To aim for as much development as
practicable to contribute to modal shift: When should a travel plan
be required?
• No firm answer
• Urban/rural - separate/simple thresholds
• Enforcement issues for small development; measures approach/set conditions
may be best
• Employment developments focus re. targets and enforcement
• Growth point sites and exception sites a priority
Protocol element 2. To ensure that good quality cycle parking
and other on-site physical facilities support new development:
What should be provided?
• Clear steer needed early for developers – but not too prescriptive
• Degree of detail required in travel plans at validation needs clarifying
• Density of development vs. infrastructure included on site is a consideration
• Pre-application talks needs stakeholder inclusivity
• Philosophical differences in approach between those involved
• Checking travel plan provisions requires resource
Protocol element 3. To apply a consistent process for the delivery
of promised outcomes: How should travel plans be delivered?
• s106 agreements preferred method, but need to link to thresholds and
enforcement priorities
• Set of conditions needed for smaller sites
• Sanctions good for ressie as lack of management structure - commuted
monitoring sum possible
• Enforcement needs knowledge, best supplied by SCC
• Iontravel.co.uk makes it easier to enforce travel plans
Protocol element 4. To undertake to work together to deliver
efficient processes and predictable decision-making: Who needs to
be involved?
• SCC role for the technical elements
• Collaborative way forward
• Minimum validation standards – need for Contents Checklist for travel plans on
8
DC websites
• Clear but overlapping/joint county/district phases of involvement
• iOnTRAVEL obligations necessary
• Area-specific modal shift targets could be set
• Standardised s106 should help
• Transition from development control to development management favours the
use of travel plans
• Member engagement and support will be necessary
• Halo examples of developments would help build the case
9
Appendix 3.
SOMERSET DEVELOPERS’ TRAVEL PLANS DRAFT SPD PRECONSULTATION
Somerset County Council and the Local Planning Authorities (LPAs) in
Somerset have been working with developers for many years to implement
smarter travel strategies in new developments.
Government guidance now recommends that such advice be brought together
in a formal planning document. Somerset County Council as the lead authority
for travel plans in Somerset has, with help of the LPAs, put together a draft
guidance document.
It is planned for this guidance to assume the status of a Supplementary
Planning Document attached to district council’s emerging Local Development
Frameworks. We are at this stage conducting a non-formal early consultation
on the document to seek feedback on its requirements.
In particular, we are asking:
• Is the process we have set out realistic (e.g. Figure 2, p19)?
• Is the content of travel plans and related obligations reasonable (e.g.
Section 3.1.2, Section 5)?
• Is the guidance clear, useful and easy to follow?
• Do any of the requirements depart from ‘normal’ practice?
• Is the draft s106 template schedule for travel plans reasonable
(appendix)?
• How does the Somerset guidance compare to other guidance you have
been required to follow elsewhere outside of Somerset?
We would be very grateful for your views, and do intend on making necessary
alterations to make the process of delivering travel plans through new
developments streamlined and easy for developers. Your input will greatly
assist in this.
We would like to give developers six weeks to provide comments on the
guidance at this stage. We would therefore very much appreciate comments
by 26th February 2010. A feedback sheet is attached which should be
returned to Reggie Tricker (C7, County Hall, Taunton, TA1 4DY) by post, or
by email to [email protected]
10
Appendix 4
Developer feedback – travel plans SPD
Summary
Firms contacted:
Firms responding:
Period for comments:
10
2
25 Jan 10 – 26 Feb 10
Points raised
General
Both supported principle of travel plans. One response particularly concerned the
level of detail in the requirements, the other focussed primarily on issues of
legitimacy and authority in the LHA asserting its requirements.
Process issues




Pre-application discussions should not be framed as a ‘requirement’
Fees are acceptable but must not cover pre-application discussions; ideally
monitoring fees should part of the planning fee
Enforcement rights are unclear/may be unreasonable
Need to treat outline and full applications differently
Content issues






Measures to be included within the travel plan seem prescriptive
Measures must be tiered to indicate those appropriate for smaller developments
LHA should not prescribe who private firms employ and how they are qualified –
i.e. the travel plan coordinator; “it is entirely a matter how private companies
structure their staff establishment and entirely a matter for those companies to
determine how to deliver their relevant Travel Plan requirements and
responsibilities.”
Too much detail on measures: noticeboard dimensions
Requiring lots of cycle parking impacts adversely upon scheme design, layout,
density and aesthetics
Minimum travel survey response rate unreasonable
Clarity issues

S106 template requires more definitions: development, developer,
commencement, occupier, householder, tenure; green travel voucher needs
further defining
11
Other


Travel plans ‘disadvantage’ occupiers of newly built offices over existing
buildings
Developers cannot control behaviour of occupiers
12
Appendix 5.
Schedule of Representations submitted on the
Sedgemoor Travel Plan SPD
(14th August to the 25th September 2012)
Page
CONTENTS
SECTION 1 – INTRODUCTION
2
SECTION 1.2 – WHEN ARE TRAVEL PLANS REQUIRED IN
SEDGEMOOR
6
SECTION 3 – PREPARING THE CONTENTS OF THE TRAVEL
PLAN
11
SECTION 4 – STANDARDS AND SPECIFICATIONS OF
PHYSICAL ON-SITE INFRASTRUCTURE
13
SECTION 5 – SECURING TRAVEL PLANS
15
SECTION 6 – IMPLEMENTING, MANAGING AND
MONITORING THE TRAVEL PLAN
16
OVERALL COMMENTS ON SPD
17
1
Introduction
The Council has consulted on a new Supplementary Planning Document (SPD) based on guidance prepared by Somerset
County Council. This guidance has been offered to Local Planning Authorities as the basis of an SPD to be adopted as
part of each Authority's Local Development Framework.
The document sets out to ensure that proposed developments contribute to the take-up of more sustainable modes of travel by
requiring travel plans to be approved prior to planning permission being granted, and ensuring that these are delivered and
monitored effectively.
In order to achieve this, standards are set out which give clear direction to developers and describe :

When a travel plan is required

An outline of the expected content and when different types of travel plan are required

The process of gaining travel plan approval

Arrangements for the monitoring and ongoing auditing of travel plans

Procedures for the effective operation and enforcement of travel plans

The respective responsibilities of all the parties involved in developing, implementing and monitoring travel plans.
The document aims to ensure consistency in process and in standards across Somerset.
Comments were invited on the draft version of the SPD between 14th August and 25th September 2012. This schedule sets out the
comments received, the Council’s response and any changes made to the SPD as a result.
2
SECTION 1 – INTRODUCTION
Do you agree with the information or approach set out in this section?
Name /
Orgn
ID
No.
Yes /
No
Comment
SDC Response
Proposed Change
Bourne
Leisure
01
No
By way of general comment, reference is made
throughout the draft SPD to national planning guidance
(e.g. PPS3 and PPG13) that has been replaced by the
National Planning Policy Framework (NPPF). All of the out
of date references to old national planning guidance
should be deleted and the national policy references in
the draft SPD amended as necessary to reflect fully the
publication of the NPPF in March, 2012.
Accepted
Remove outdated references
Cheddar
Parish Council
04
Executive Summary
No one on the Parish Council is an expert on the subject
of this consultation, therefore starting with the Executive
Summary it is unclear that this travel plan relates to all
developments including residential ones. The references
to residential travel plans throughout the document as a
whole suggest that the whole exercise is relating to
commercial & industrial premises, certainly the exec
summary gives this impression.
The Exec Summary does not
mention specific types of
development, but refers to new
development as a whole. The
table on page 19 identifies which
type of development requires
which type of travel plan, and
includes residential.
No change
Accepted
Add ‘residents’ to TVS5
For example......in Executive summary page 8 second
paragraph ‘to ensure that proposed developments
contribute to modal shift’..........one presumes this means
ALL developments including residential but as stated
above residential developments are rarely referred to
throughout the whole document, let alone mentioned in
the summary.
Also page 8 TVS5 Full travel plans...........second bullet
‘An action plan of new initiatives to improve travel options
for staff, customers and visitors’. This does not mention
residents, but then TVS5 may be specific to commercial
premises (we don’t know). Again TVS6 bullet refers to ‘a
member of staff’ to act as travel plan co-ordinator’....this
couldn’t apply to a residential site. Who would it be if it
was residential? Page 67 hardly answers the question,
and yet here is a paragraph dedicated to managing
residential travel plans.
Suffice to say the Executive summary doesn’t mention
residential developments at all.
Page 9 bullet point TVS14..........’Travel Plans may be
safeguarded with measures etc etc, is not a clear positive
statement. Was it intended to imply that they may also
NOT be safeguarded? That’s fine if that was the intention
of the statement.
Cheddar
Parish Council
04
Introduction
Page 13..............reference to ‘Thresholds for travel plans
are provided in Table 2’ ...is this required here? It is
repeated on page 17.
Page 14 Footnote numbering is wrong. There is no
footnote 56. Also there is no note for footnote 6 so need
to number 5 & 6 individually clearer.
Page 16, the diagram of three documents is not worth
putting in, since in the statement above it implies that the
relative size of the development dictates/ determines
which document is used. As nothing more is added by the
diagram and it obscures the printed footnote on our
downloaded version it is a nuisance that adds no value.
Page 17 Mentions TVS1 Table 2, would be useful to give
page number, Page 1 gives the table’s title but table on
page 19 is untitled, but is it table two?
Page 17 second paragraph refers to Table 2 part
a..................but the table isn’t labelled 2 part a, as far as
I can see, therefore uncertain as to what this refers to.
Page s 21 & 22 are presumably Table 2 parts c & d?
1
The word ‘may’ is used to
indicate that these measures will
be used where appropriate, but
that they may not be appropriate
in every case.
No change
Accepted
Remove sentence
Accepted
Amend footnote numbering
Graphics are used to improve
visual appearance
Adjust graphic
Accepted
Amend
Table parts are labelled and
coloured differently
No change
Table 2 confirms this document is concerned with
commercial premises, therefore just a mention in the
index or exec summary would direct a casual reader to
the few references they may be interested in regarding
residential developments without the need to read the
whole document.
Highways
Agency
05
Yes
Table 2 includes residential,
which is listed as the planning
use class C3 together with the
threshold number of dwellings
that would trigger different types
of travel plan
Include sentence in ‘Purpose
of the Document’ to clarify
that the document is
concerned with all types of
development.
There are references to PPGs/PPS that have now been
withdrawn
Accepted
Remove references
It would be useful to make reference to the TP pyramid.
This gives strong emphasis to master planning issues
While it is accepted that the
diagram may be useful in
understanding travel planning, it
is not considered to add enough
to the text already in the draft
SPD to justify the extra space
and text it would require.
No change
2
We suggest stronger emphasis to requiring that part of the
TP setting out how the internal layout and links relate and
function with the surrounding sustainable travel networks.
Noted. This is a detailed matter
that should be addressed in
individual Travel Plans.
No change
SECTION 1.2 – WHEN ARE TRAVEL PLANS REQUIRED IN SEDGEMOOR
Do you agree with the information or approach set out in this section?
Name /
Orgn
ID
No.
Yes /
No
Comment
SDC Response
Proposed Change
Bourne
Leisure
01
No
With regard to the detail of the consultation document,
Bourne Leisure endorses the first paragraph on page 12
of the draft SPD which states:
“Travel plans are unique and specific to each
development site…”.
This statement clearly reflects the unique nature of any
one development proposal and the Company therefore
objects to the proposed introduction via the SPD of
thresholds (TVS1) to determine the need for travel plans
for development proposals that are simply categorised
under land use types and Use Classes, and as detailed in
Table 2.
The use of thresholds is
considered necessary to ensure
consistency of approach across
Somerset. It is expected that
individual travel plans will be
developed in negotiation with
the Local Highways Authority
and that they will need to be
achievable and appropriate to
the development concerned.
Text explaining the status of
the document to be added to
‘Purpose of this Document’.
In short, the starting position for the negotiation and
determination of whether or not development proposals
require a Travel Plan should be based on the merits and
travel benefits/ impacts of a development proposal and
not an arbitrary threshold relating to a Use
3
The SPD sets out guidelines
which should be followed unless
other considerations indicate
otherwise.
Class.
Whilst the Company endorses the objectives which the
Council refer to travel plans as seeking to deliver, there is
a clear need to approach development proposals on an
individual and site by site basis so as to be able to take
site specific circumstances fully into account.
This different approach would be justifiable, for example,
in the case of our clients’ developments, and for other
developments that cater for the visitor economy in
Sedgemoor.
With regard to such facilities, they are often located where
there is no feasible alternative available other than the
private car for reaching the tourist-related developments
that are long-established in more remote and/ or rural
areas. It would be inappropriate to impose standard travel
plan requirements that are not appropriate for a particular
site, by the imposition of uniform standards.
Our client therefore sees it as vitally important that
arbitrary thresholds are not introduced through the draft
SPD for the requirement of a travel plan for development
proposals.
The draft SPD should therefore be amended to omit Table
2, with specific emphasis included on the need for preapplication discussions, including potential travel plan
requirements.
4
SECTION 2 – DELIVERING A TRAVEL PLAN THROUGH THE PLANNING PROCESS
Do you agree with the information or approach set out in this section?
Name /
Orgn
ID
No.
Yes /
No
Comment
Bourne
Leisure
01
No
Pre-application discussions
Bourne Leisure endorses the approach summarised in
Section 2.1 of the draft SPD, which advises that the need
for a travel plan will be established through discussions
with the local planning authority (LPA) at the preapplication stage.
Cheddar
Parish Council
04
SDC Response
Proposed Change
In light of the above draft SPD advice, the necessity to
approach each development proposal on its own merits is
clear. Bourne Leisure considers that the use of thresholds
to guide such discussions on travel plan requirements
presents the very clear danger of such thresholds
being used inflexibly and not as a starting point for
discussions but rather as a standard (as they are named),
and ultimately as a validation requirement. Therefore in
the spirit of encouraging pre-application discussions with
the LPA that will lead to the submission of a planning
application scheme that is acceptable to the applicant,
LPA and the local community alike, our client sees it as
being vitally important that arbitrary thresholds are not
introduced through the draft SPD for the requirement of a
travel plan for development proposals.
The use of thresholds is
considered necessary to ensure
consistency of approach across
Somerset. It is expected that
individual travel plans will be
developed in negotiation with
the Local Highways Authority
and that they will need to be
achievable and appropriate to
the development concerned.
Text explaining the status of
the document to be added to
‘Purpose of this Document’
Page 25 Paragraph 2. LPA is not an abbreviation of
District Council. Therefore LPA needs defining the first
time Local Planning Authority is used in full & before it is
abbreviated later on.
The abbreviation LHA was explained in paragraph 2 &
need not be restated in para 4.
Accepted
Amend
Accepted
Amend
5
The SPD sets out guidelines
which should be followed unless
other considerations indicate
otherwise.
Highways
Agency
05
Yes
Page 28, why is this text boxed? Is it because it is a
policy statement? Does the policy have a number?
Page 29 Para 2, where are table 2 and SECTION 3?
th
Page 31 4 box in right hand column, I don’t think the
abbreviation ‘TA’ has been used before or explained,
could be wrong, death by abbreviation at this point.
Overall we agree with the information & approach in this
section
This is the HA’s position
Accepted
No change
Amend
1. The planning policy framework changes require that the
reference to the HA need to be amended. Please use the
text below:
Accepted
Make suggested change
The LHA works together with the HA to provide comments
on developments with travel plans. Further explanations of
the HA’s specific requirements are provided as follows.
Planning Policy:
1. The Highways Agency (HA) has a policy to
promote travel plans as an integral part of
managing the capacity of the trunk road network
(Circular 02/2007). The Highways Agency follows
the following hierarchical approach in undertaking
its planning role, namely:
1. direction of development to sustainable
locations (through development plan
allocations);
2. minimization of travel demand (through
the implementation of travel plans)
3. management of residual demand to
constrain flows within the existing
capacity of the highway network; and
4. capacity enhancement only as a last,
undesirable resort, and then to be
delivered through the Plan-making
process.
6
Under Circular 02/07, a ten year assessment period is
used.
The Agency’s approach to promoting Travel Plans
supports the Department of Transport’s (DfT) overall
environment and climate change objectives.
For developments that could significantly impact on the
trunk road network, representatives of the Highways
Agency should be consulted throughout the process from
the earliest pre-application stage. The current Highways
Agency policy is to manage further traffic growth on its
highway network by exploiting fully the opportunities
provided by travel plans.
The Highways Agency would expect a travel plan to be
submitted with a planning application to include:
the identification of targets based on transport
assessment. These are normally trip based
the methods to be employed to meet these targets
detailed travel plan management arrangements
including identification of travel plan co-ordinator
the mechanisms for monitoring and review, taking into
account phasing of the development
the mechanisms for reporting
the remedial actions in the event that targets are not
met
the mechanisms for mitigation
implementation of the Travel Plan to an agreed
timescale or timetable and its operation thereafter,
including actions on how it is to be managed
where appropriate, financial provision for
implementation and remedial measures
The Highways Agency’s approach to travel plans is
focused on outcomes. All plans are tested against their
7
ability to ensure that ‘severe’ conditions trunk road
network are avoided. This approach is set out in NPPF.
It is essential that travel plans are rigorously monitored in
order that an understanding of the effectiveness of the
plan can be gained. This is useful to understand what
changes have occurred over the period and also informs
the LHA and Highways Agency to understand whether
travel plan obligations or conditions are being met.
The acceptability of the Travel Plan will need to be agreed
in writing by the Local Planning Authority and Local
Highway Authority (in consultation with the HA on behalf
of the Secretary of State for Transport), in advance of
commencement or occupation of the development.
SECTION 3 – PREPARING THE CONTENTS OF THE TRAVEL PLAN
Do you agree with the information or approach set out in this section?
Name /
Orgn
ID
No.
Yes /
No
Comment
Bourne
Leisure
01
Yes
No comments
SDC Response
8
Proposed Change
Cheddar
Parish Council
Highways
Agency
04
05
Yes
Page 34, Item 3..............Don’t think MfTPs has been
explained previously except in footnote 23 bottom of
page 32..before being used as an abbreviation here
(could be wrong but fed up with trying to read this by now)
Page 34.....................This could be an opportunity to
make reference to residential developments if that applies.
Then whole of section 3 could be read in that light.
Page 37....The value of the increasing strength of travel
plan diagram is doubtful it states, ‘enable, enable,
exemplify, educate, encourage & enforce’................
If this is related to table 4 then....this table refers to
‘educate, exemplify, encourage, & enforce... not in the
same order, & no mention of ‘enable & enable’ and not in
the same order....so what value is it?? It confused me.
Page 40 Should ‘Site Plan Co-ordinator’ be a title? As
the rest follows on from this?
Locker & Shower rooms, gets a bit lost in the overall
text....should it be a title?
Page 44.......................We are not sure what ‘30%
reduction in the Census figures’ refers to. Which aspect
of the census figures in particular is being used as a
measure?
Overall we agree the approach in this section
Accepted
Amend
Noted
No change
Accepted
Amend
This is clear from the text above
No change
We suggest stronger emphasis to requiring that part of the
TP setting out how the internal layout and links relate and
function with the surrounding sustainable travel networks.
This is sometimes provided as part of the TA
documentation but is often not seen as a TP issue.
Noted. This is a detailed matter
that should be addressed in
individual Travel Plans.
No change
Timescales should be agreed
during pre-application
discussions, and Planning
Performance Agreements used
where appropriate. It would be
unreasonable to demand the
submission of Travel Plans in
advance of submission of the
Add text in section 2.1
referencing the use of PPAs
to set timescales, where
appropriate.
In figure 2, it might be helpful to suggest a timescale for
submission of the TP on advance of the PA being
submitted (e.g. 2 weeks).
More emphasis could be given to measures that reduce
the need to travel.
9
planning application
SECTION 4 – STANDARDS AND SPECIFICATIONS OF PHYSICAL ON-SITE INFRASTRUCTURE
Do you agree with the information or approach set out in this section?
Name /
Orgn
ID
No.
Yes /
No
Comment
SDC Response
Proposed Change
Bourne
Leisure
01
No
Whilst Bourne Leisure endorses the principle of physical
on-site travel plan measures seeking to influence travel
behaviour, the application of such measures without
thorough consideration of the individual characteristics of
development proposals on a site by site basis is a cause
for serious concern.
It is expected that Travel Plans
will be developed in consultation
with the Local Highways
Authority and that they will be
deliverable and appropriate to
the development concerned.
Text explaining the status of
the document to be added to
‘Purpose of this Document’
As advised previously with reference to our client’s
operations, there is often no feasible alternative available
other than the private car for reaching tourist-related
developments in more remote and/ or rural areas. Indeed,
the necessity of car travel in certain circumstances
is recognised in the CLG Good Practice Guide “Planning
for Tourism “(2006). This guidance has not been replaced
by the NPPF and paragraph 5.3 states:
“Planners will need to recognise that the wide variety of
development that are inherent in the
tourism industry means that there are some
developments… that are car dependent”
The SPD sets out guidelines
which should be followed unless
other considerations indicate
otherwise.
10
In the light of the above, Bourne Leisure sees it vitally
important that Section 4 of the draft SPD is amended to
reflect Government guidance, to specifically acknowledge
the unique nature of tourist-related development and
therefore the necessity to approach the matter of
physical on-site infrastructure with flexibility.
Cheddar
Parish Council
Highways
Agency
04
05
Yes
Yes
Section 4.0 should there be reference to lighting to make
environment feel safer, in the list of physical travel plan
measures?
Should there also be reference to company sponsored
coach/bus at some point here and if so then allowing for
parking & turning circles of such vehicles?
Page 55 last line in box......................residential long term
parking is mentioned.....is this residential homes or are
housing developments coming into the document here.
Also page 56 residential is now in the document, unless
this means residential homes rather than individual
dwellings?
Overall we agree with the approach in this section.
No comments
11
Noted. These are detailed
matters which can be addressed
in individual Travel Plans.
Both references refer to any
residential development,
whether housing or residential
homes.
No change
SECTION 5 – SECURING TRAVEL PLANS
Do you agree with the information or approach set out in this section?
Name /
Orgn
ID
No.
Yes /
No
Comment
Bourne
Leisure
01
Yes
No comments
Cheddar
Parish Council
04
Yes
No comments
Highways
Agency
05
Yes
As the HA cannot be a party to a s106 we would ask that
on developments with significant implications for the
Strategic Road Network , we have a chance to review in
relation to TP obligations prior to signing the s106 by the
LHA/LPA.
12
SDC Response
Proposed Change
Accepted
Add sentence to this effect in
section 5.
SECTION 6 – IMPLEMENTING, MANAGING AND MONITORING THE TRAVEL PLAN
Do you agree with the information or approach set out in this section?
Name /
Orgn
ID
No.
Yes /
No
Comment
Bourne
Leisure
01
Yes
No comments
Cheddar
Parish Council
04
Yes
No comments
SDC Response
13
Proposed Change
Highways
Agency
05
Yes
We tend to encourage use of traffic counters so that they
can be related to trips rates agreed in the TA
The use of traffic counters is
required in TVS15
No Change
OVERALL COMMENTS ON SPD
Overall, do you agree with the approaches set out in the Draft SPD?
Name /
Orgn
ID
No.
Yes /
No
Comment
SDC Response
Proposed Change
Bourne
Leisure
01
No
Bourne Leisure supports, in principle, the use of travel plans
where necessary and through the planning system, to
contribute to modal shift via development proposals. The
Company however considers it vitally important that travel
plans are only used in appropriate circumstances. The need
for, and the scope of any one travel plan should be
established on a site by site basis, through clear dialogue
with the LPA during pre-application discussions.
Bourne Leisure considers that the draft SPD as currently
being consulted on presents an overly onerous policy
position. The proposed thresholds at which a travel plan
would be required present the danger of becoming nonnegotiable ‘trigger points’ which could undermine the
The use of thresholds is
considered necessary to
ensure consistency of
approach across Somerset. It
is expected that individual
travel plans will be developed
in negotiation with the Local
Highways Authority and that
they will need to be
achievable and appropriate
to the development
concerned.
Text explaining the status of
the document to be added to
‘Purpose of this Document’
14
important role that pre-application discussions should fulfil.
Our client therefore sees it as vitally important that no
arbitrary thresholds are introduced through the draft SPD for
the requirement of a travel plan for development proposals.
The draft SPD should therefore be amended to omit Table 2,
with specific emphasis in the draft SPD instead included on
the role of pre-application discussions, including them
covering travel plan requirements.
Bridgwater
College
02
Firstly, the document, the technical wording and potentially
the scheme itself needs to be considerably simplified! There
is a need to get people to buy into the scheme if it is to
succeed and this document makes it very difficult for a wide
range of people to easily understand what is proposed and
thus to try and implement it.
The College is supportive of encouraging staff, students and
visitors to make best use of non-car transport to help reduce
the College’s overall carbon output and improve health;
indeed we already do much work to both achieve this as well
as providing a large educational input to our students on this
subject across the spectrum of courses. We would not wish
to implement any scheme that impacted on students not
being able to attend the College, especially those with very
limited financial resources.
To justify the additional costs and considerable efforts
involved, organisations would need to see that this is a
‘joined-up’ process in that the fees involved in this process
would be directly invested back into alternative transport
methods (i.e. additional cycle lanes, easier access to the
railway station, improved pavements and additional
walkways, improved bus services).
Any travel plan needs to be flexible to take into account the
nature of the organisation, its location etc. We do not
15
The SPD sets out guidelines
which should be followed
unless other considerations
indicate otherwise.
The document is aimed at
developers and new
development rather than the
general public. The Local
Highways Authority will be
able to provide support with
interpreting the document
and developing travel plans
for individual developments.
Spending on transport
infrastructure is generally
within the power of the Local
Highways Authority, although
section 106 agreements are
sometimes used to ensure
that new development
contributes to such
infrastructure. Through the
new Community
Infrastructure Levy
No change
consider that you can effectively enforce a fixed scheme that
is appropriate for the wide range of
developments/organisations within Sedgemoor. It will not
work if a scheme is forced on an organisation where it is not
appropriate and where it will cause issues outside of a
particular development (i.e. encourage visitors to park in local
housing areas adjacent to the development where this would
cause significant issues for local residents).
Councils also need to be aware of the impact of the
additional costs being placed on organisations that these
proposals will inevitably incur. Many organisations may not
be in a position to be able to afford the additional costs
especially employing staff to manage a travel plan.
There needs to be recognition in any travel plan of actions by
either the County Council or District Council that have a
significant impact on any travel plan. An example is the
County Council’s significant cuts in grants to student bus
passes that makes it more cost effective in some cases for
students to drive to College that makes effective
implementation of a travel plan rather more difficult. In
addition, many of our staff and students live in rural
communities where travel options are limited and in these
areas some bus routes have been or are planned to be
cut/reduced. Any plan therefore needs the involvement of all
parties to ensure that it is fair and that all relevant factors are
taken into account to make any targets realistic and
achievable.
16
developers will also be
required to contribute
towards new strategic
infrastructure.
It is expected that Travel
Plans will be developed in
consultation with the Local
Highways Authority and that
they will be deliverable and
appropriate to the
development concerned.
The SPD is only of relevance
to new development. The
costs of travel planning
already need to be taken into
account by developers, and
the SPD should not impose
significant extra costs.
This is a valid point that
needs to be addressed
through joined-up strategic
transport planning.
Bridgwater
Town Council
03
Request plain English - not gobbledegook of
original.
BTC will continue to dispute 'County' standards for car
parking - which is never sufficient to meet needs and needs
to get some realism into it.
This is a technical document
aimed at developers and
planners rather than the
general public. The Local
Highways Authority will be
able to provide support in
interpreting the document
and developing travel plans.
No change
Car parking standards are a
matter separate from this
document.
Cheddar
Parish Council
04
Comments can be found throughout this response and
include that there are some errors in the text around
footnotes. Diagrams are not well labelled.
Individual comments have
been responded to.
Some diagrams are not required or are confusing.
Residential developments are rarely mentioned & when they
are it’s late in the document and almost in passing. This
makes it difficult for consultees such as parish councils to
recognise that they may need to be considering a travel plan
from residential developers in their areas.
There is concern that the costs this could load on to an
employer, or potential employer could be enough to deter
them from bringing their jobs to our area.
17
Given the technical nature of
travel plans, it is expected
that the Local Highways
Authority in conjunction with
the District Council will judge
the adequacy and suitability
of travel plans, although text
should be added to
encourage local consultation
on the measures suggested
in travel plans for major
development.
Developers already need to
take travel planning cost into
account. This SPD is not
expected to add significantly
to these costs to an extent
Add text to section 2.1 to
encourage developers to
consult locally on measures
suggested in their travel
plans when they consult on
planning proposals.
Highways
Agency
Natural
England
05
06
Yes
The document is designed for a single individual to reply to,
you may wish to consider making the response form suitable
for a group reply such as this from a Parish Council as a
body, not from an individual.
that affect viability.
We provided input into Somerset CC’s SPD at the draft stage
and support the general approach particularly in relation to
monitoring and failsafe. It may be necessary to review the
failsafe formula from time to time.
The SPD will be reviewed in
line with the Core Strategy.
Add text to section 6.1
setting out a timetable for
review of the document.
The SDP should seek to get a balance between ensuring that
a robust travel plan with teeth is secured, whilst minimising
unwanted detail. For example, travel plans in their
accessibility sections often list bus services; rail services;
footway; cycle track etc without giving a real insight into
overall accessibility and links to key destinations.
Noted. It is considered that
the SPD will help with this
point.
No change.
We can see nothing within the above documents that is likely
to affect any of Natural England’s concerns and we therefore
make a return of ‘no comment’. Should you become aware of
anything that you believe may be of interest to us then please
do not hesitate to make contact again.
Noted
No change
The lack of further comment from Natural England should not
be interpreted as a statement that there are no impacts on
the natural environment. Other bodies and individuals may be
able to make comments that will help the Local Planning
Authority (LPA) to fully take account of the environmental
value of areas affected by this plan in the decision making
process.
18
Noted
Network Rail
07
Level Crossings
Development proposals’ affecting the safety of level
crossings is an extremely important consideration for
emerging planning policy to address. The impact from
development can result in a significant increase in the
vehicular and/or pedestrian traffic utilising a crossing which in
turn impacts upon safety and service provision.
As a result of increased patronage, Network Rail could be
forced to reduce train line speed in direct correlation to the
increase in vehicular and pedestrian traffic using a crossing.
This would have severe consequences for the timetabling of
trains and would also effectively frustrate any future train
service improvements. This would be in direct conflict with
strategic and government aims of improving rail services.
In this regard, we would request that the potential impacts
from development affecting Network Rail’s level crossings, is
specifically addressed through planning policy as there have
been instances whereby Network Rail has not been
consulted as statutory undertaker where a proposal has
impacted on a level crossing.
As such, we strongly believe that the importance of Level
Crossing safety warrants a specific Policy included in the
Document which will help to elevate the importance of Level
Crossings within the development management and planning
process. We request that a policy is provided confirming
that:

The Council have a statutory responsibility under
planning legislation to consult the statutory rail
undertaker where a proposal for development is
likely to result in a material increase in the volume or
a material change in the character of traffic using a
level crossing over a railway:
19
This is a matter for general
planning policy and for the
development management
process, rather than this
document. These comments
will be forwarded to the
relevant people.
The matter has limited
relevance for Sedgemoor,
given the lack of level
crossings.
No change
o
Somerset
County
Council
08
Yes
Schedule 5 (f)(ii) of the Town & Country
Planning (Development Management
Procedure) order, 2010 requires that…
“Where any proposed development is likely
to result in a material increase in volume or a
material change in the character of traffic
using a level crossing over a railway (public
footpath, public or private road) the Planning
Authority’s Highway Engineer must submit
details to both Her Majesty’s Railway
Inspectorate and Network Rail for separate
approval”.

As a first principle, Network Rail would seek to close
Level Crossings where possible.

Any planning application which may increase the
level of pedestrian and/or vehicular usage at a level
crossing should be supported by a full Transport
Assessment assessing such impact: and

The developer is required to fund any required
qualitative improvements to the level crossing as a
direct result of the development proposed.
1.) We welcome that the Council is planning to adopt
Somerset County Council’s model Travel Planning SPD. This
will assist in establishing a standard approach to travel
planning across the County. In this context,
please note that we anticipate the need to review the
arrangements on travel planning fees soon and will work
closely with District Council colleagues on this matter.
2.) Please note that a new Travel Plan Coordinator has been
20
Noted
Amend
appointed by SCC’s Strategic Planning Team. Please would
you kindly update the contact
details at the end of the SPD and the Travel Plan Fees
document as follows:
Dan Carey
Travel Plan Coordinator
Somerset County Council
C702a County Hall
Taunton
TA1 4DY
Email: [email protected]
Phone: 01823 358079
21
22