Suffolk Coastal Local Plan - Final Draft

Document Section Final Draft Local Plan 7 Transport Sustainable Transport Policy SCLP7.1: Sustainable Transport [View all comments on this section]
Comment ID 1079
Respondent Suffolk County Council (N/A) [View all comments by this respondent]
Response Date 25 Feb 2019
Do you consider this part of the Plan has met the tests of soundness? No
Do you consider this part of the Plan to be unsound because it's not:
  • Effective
  • Consistent with national policy
Details of Representation

The County Council welcomes the steps that the District Council has made to improve clarity around the point at which development should be prevented, however it is now notable that the policy does not make specific reference to the requirement in paragraph 108 c) of the NPPF for cost-effective limitation of significant highway impacts. Whilst this provision is included in the NPPF, the absence of this clause in the policy suggests that it is not relevant in the context of Suffolk Coastal.

Furthermore, there are several residential allocations in this Plan which are not within safe walking distance of primary schools (for example sites 12.46, 12.54 and 12.60), which are likely to lead to unsustainable modes of travel and an ongoing cost to the taxpayer to transport some of those children to school. Sites should be required to consider how they can ensure that safe and sustainable routes to school are available, and the County Council reserves the right to seek a proportionate contribution to home to school transport where a safe route cannot be provided. The cost of transport varies significantly based on the circumstances, but based on an average cost of £960 per child in Suffolk per annum, this could amount to £2,500 per dwelling for sites which are not within 2 miles safe walking distance of a primary school and also not within 3 miles safe walking distance of a secondary school. Windfall sites may also present this challenge.

Policy 7.1 offers one way to steer development to make routes to school safe, in line with the NPPF requirement to actively manage patterns of growth to promote healthy and sustainable travel (paragraphs 102, 103 and 91).

Please set out what change(s) you consider necessary to make the Local Plan legally compliant or sound

In order to make the Plan sound and in line with the new NPPF, the policy should be amended. Alternative amendments may be required, subject to consideration given to comments on Policy 2.2 (above). The current clause g) should be deleted and replaced with the following

f) it will improve public transport in the District and takes available opportunities to ensure safe and sustainable access to local schools; and

g) Significant impacts on the highway network are limited through promotion of sustainable travel and improvements to the capacity of the network. Development will be prevented when impacts on safety are unacceptable or residual cumulative impacts on the network are severe.

If your representation is seeking a change, do you consider it necessary to participate in the public examination?
  • Yes, I wish to participate at the oral examination
If you wish to participate in the public examination, please outline why you consider it to be necessary:

the County Council would be pleased to appear at the local plan examination, alongside and in support of the District Council, to help the Inspector consider matters relevant to the County Council and its responsibilities. We would be pleased to discuss this with the appointed Programme Officer, once the examination Matters and Questions are published.

Being kept informed
  • No, I do not wish to be kept informed of future progress of the plan