Background
The Chamber is responding to the Department of Environment, Transport and the Region's consultation on the revision of PPG13, the planning policy guidance on transport.

The department has asked for responses to 18 questions about the guidance. The chamber has responded to these questions, where we have competence and where our membership is affected. The Chamber's submission on PPG13 also includes some general comments about our approach to planning policy in relation to transport in the Thames Valley, as background to our responses to the Department's specific questions.

About the Chamber
Thames Valley Chamber is a regional chamber covering the counties of Buckinghamshire, Berkshire and Oxfordshire. With over 3,500 members it is the second largest chamber in the UK. Members include some of the largest companies in the UK such as Microsoft, Vodafone, Panasonic, Mars and Amersham International.

The Thames Valley
The Thames Valley is a powerhouse of the UK economy and the best performing region in the UK outside London, with a GDP of £22 billion. The region is the leading high-tech area in the UK, home to market leaders in electronics, IT, telecoms, pharmaceuticals and biotechnology. Leading companies include Bayer, Microsoft, Oracle Corporation, Vodafone and Rover.

Unemployment is 1.6%, and it is estimated that the economy's growth will mean a shortfall of 67,000 workers by 2010 .

However this success has led to a number of pressures on existing infrastructure:

Pressure on existing transport infrastructure to the point where demand exceeds capacity on roads, rail and bus networks. This congestion adds substantially to business costs and affects our region's competitiveness.
Demand for commercial land means that new sites for development are very scarce, and generally of poor quality. Therefore, business finds it difficult to re-invest and grow, and investment in the region is deterred.
A lack of affordable housing adds to the skills and people shortage in the Thames Valley. Companies find it difficult to recruit as there is virtually full employment in the region and new labour is discouraged from re-locating into the Thames Valley because of the cost and shortage of available housing.
An urgent need for modernisation and streamlining of the planning process. Costs associated with the complexity and speed of obtaining planning consents adds greatly to the burdens on business and discourages a flexible response to changing market conditions.

Our Approach to PPG13

On examining any proposals from Government our guiding principle is to consider the impact on business in the Thames Valley, whilst being aware of the wider environmental and social impact of policy. It is from this perspective that our submission is made.

Our Position

We welcome the government's review of PPG13, but we have reservations about the effectiveness of guidance in delivering the improvements that our region needs, without substantial investment in public transport. However, we support the Government's aim of "better integration between planning and transport and between different modes and to achieve a more consistent implementation of the existing policy approach".

The Chamber is concerned about traffic congestion in the Thames Valley. Current growth in traffic is unsustainable, yet at present there is no alternative to the car for business in the Thames Valley.

Congestion in the Thames Valley needs to be urgently addressed. The Thames Valley is a key driver of the UK economy and must be free to compete in global markets. Current congestion is endangering our region's competitiveness and businesses' ability to respond to the demands of global markets. Standing still is not an option; business demands continual change and improvement to meet the needs placed upon it by its customer base. If the Thames Valley does not meet these needs, we will lose key businesses. We believe this cannot be allowed to happen.

The region is relatively well served by rail from London but links north south links in the region are poor, both by road and rail. There are also a number of severe bottlenecks in the road network (e.g. Handy Cross M40 interchange, M4 junctions from Reading to the M25).

The Chamber believes that the only way forward is substantial up-front investment in public transport infrastructure as an urgent priority. We support the bid for a Western Connection rail link and urgent action at the Handy Cross interchange as immediate priorities. We believe that park and ride schemes can help reduce congestion in town centres, but only if they are properly resourced and meet real needs of commuters in terms of frequency and duration of services and choice of destination.

We are opposed to the introduction of work place parking charges and congestion charging because of the negative impact this will have on Thames Valley business. These charges are being proposed at a time when there is no alternative to the car for business in the Thames Valley. To introduce these charges without alternatives to the car will not tackle congestion but simply load more taxes onto business and therefore harm wealth creation in our region.

Questions for Consultation

The Chamber has only responded to those questions where we have competence and where our membership is affected.

4. Are the phrases 'genuine choice of access' and 'realistic means of access' in paragraph 15 sufficiently clear and meaningful and, if not, how can they be improved?

No - these terms could be defined by a minimum number and frequency of public transport services and a maximum distance from access points to a site.

5. The Department is preparing good practice advice on Transport Assessments, which will also cover the handling of accessibility issues in RPG and development plans. Are there specific issues which you would like to see covered in the forthcoming guide?

There should be flexibility to meets the needs of individual businesses. Rather than 'across the board' standards, guidance should reflect the different transport needs of particular types of business. For example, professional services may need car parking spaces to accommodate cars for clients' visits, while factories sites located near public transport may not.

7. Are the maximum parking standards right?

8. Are the thresholds for the parking standards right?

We believe that there should be some flexibility depending on individual company's circumstances and needs of business and their proximity to public transport.

9. Do you have any comments on the effects of parking standards particularly on businesses, other organisations, quality of life and the level of congestion?

Standards should reflect the different transport needs of particular types of business and availability and quality of access to public transport. We believe if workplace congestion charging is introduced in the Thames Valley today, when there are no viable alternatives to the car, there will be no impact on congestion but the additional tax burden will harm business.

10. Do you have any comments on the advice that development plans should not contain any minimum parking standards?

We believe that in practice the car will continue to be an important mode of transport in the Thames Valley for the foreseeable future. Therefore there should be minimum parking standards to reflect the continuing role of the car. Developments built without minimum standards are unlikely to meet customer demand and will ultimately fail, damaging the environment that PPG13 seeks to protect.

13. Is the advice on park and ride, particularly on the treatment of schemes in green belt, clear and workable?

Our comments are based on our experience of park and ride schemes in Reading and Oxford. We believe that park and ride schemes can help reduce congestion in town centres, but only if they are properly resourced and meet real needs of commuters in terms of frequency and duration of services and choice of destination.

14. Is there sufficient advice on the relationship between planning objectives and proposals for road user and workplace parking charges and, if not, how could it be improved?

We believe there will only be a relationship between planning objectives and charging if there is a practical alternative to the car. These charges are being proposed at a time when there is no alternative to the car for business in the Thames Valley. To introduce these charges without alternatives to the car will not tackle congestion but simply load more taxes onto business and therefore harm wealth creation in our region. The Chamber will continue to press for investment in public transport.

17. Is the section on implementation (covering planning conditions and obligations and the use of green transport plans) sufficiently clear and workable and, if not, how could it be improved?

Planning Conditions
If parking spaces can be removed when access to the site is improved by public transport, we believe that it should be possible to add parking spaces if public transport access to the site is reduced.

Specification of delivery frequencies to sites must be flexible. The need for deliveries will vary with business conditions and other circumstances, and inflexible controls will severely restrict the ability of business to respond to market conditions.

Planning Obligations
Payments to local authorities "where development can only take place with improvements to public transport services" must be proportionate and reflect the wider community benefit of such investment. Business already held to random for the provision of new public infrastructure.

18. Do you have any comments on freight issues, in particular does the advice give sufficient weight to promoting transport choices and the development of transport infrastructure?

Guidance must recognise that cost and flexibility drive transport decisions by business. Alternatives to lorry freight must not be imposed; rather they should compete in terms of cost and flexibility.

Call Bill McCardle on 01865 309572 or e-mail policy@thamesvalleychamber.co.uk for more information.