Closed call for evidence

Freight, logistics and the planning system: call for evidence

Published 4 July 2023

This was published under the 2022 to 2024 Sunak Conservative government

Applies to England

Background information

Freight and logistics

The freight and logistics sector has a critical role supporting UK supply chains. It underpins the UK’s prosperity, health, wellbeing and security by maintaining the flow of goods into, out of and across the country. Every day, millions of deliveries are made in the UK.

Every parcel received at a front door, almost every good bought in a shop and every component delivered to a factory was delivered by the UK’s world-class freight and logistics sector. It is a vital pillar of the UK economy, contributing £127 billion gross value added (GVA) through more than 200,000 enterprises.

Supply chains rely upon multiple modes of freight transport along road, rail, air and maritime routes with transfers between and within modes at ports, airports, rail freight interchanges and at distribution centres and warehouses where freight is disaggregated or consolidated.

All of these transfer points require the right infrastructure in the right place for the system as a whole to function effectively.

Future of Freight: a long-term plan

Following extensive collaboration with the sector, on 15 June 2022, we published the first long-term and cross-modal plan for freight – The Future of Freight: a long-term plan. The future of Freight (FoF) set out a long-term vision for a sector that is cost-efficient, reliable, resilient, environmentally sustainable and valued by society.

It demonstrated how the sector has a role in supporting the delivery of a number of public policy priorities. As a geographically distributed employer, the sector is well placed to support growing and levelling up the economy with significant cross-border freight flows, strengthening the Union.

The sector is a facilitator for UK imports, exports and access to global markets, making it central to strengthening the UK’s global impact. Supporting the sector to achieve net zero carbon emissions, through fleet and technological changes, provision of energy infrastructure and facilitating changes to distribution models will also be central to achieving the government’s net zero ambitions.

The FoF identified the main opportunities and challenges facing the cross-modal freight and logistics sector and identified priority actions to begin addressing those opportunities and challenges.

Chapter 5 in the FoF sets out the importance of the planning system to achieving the objectives for the sector. Since publication of the plan, the government has made progress.

We have recently published the updated DfT Circular 01 2022 (replacing Circular 02 2013) on The Strategic road network and the delivery of sustainable development and we have committed to consult on updates to local transport plan guidance. We will also publish an updated manual for streets in due course.

Critically, however, the FoF committed government to publish this call for evidence to better understand the practical issues in planning for the right infrastructure to best support the freight and logistics sector, and to help us build a comprehensive picture of where the planning system can appropriately support the sector, including understanding:

• what is working well
• what could work better
• how the government can promote best practice

The planning system

In the UK, planning is devolved. This call for evidence applies only to the planning system in England. The planning system is central to some of our most important national challenges:

• it shapes the places where people live and work
• enables development to respond to climate change
• supports sustainable growth in all parts of the country to help rebalance our economy

It plays a critical role in identifying what development is needed and where, in specifying what areas need to be protected, managed or enhanced and in the delivery of sustainable development.

The planning system is the framework for managing the use of land. In a densely populated country with an advanced economy, this is particularly challenging. It seeks to optimise land use with decisions on development taken at an appropriate tier of government to ensure democratic accountability.

The system must support sustainable development and national planning policy sets out 3 overarching objectives to achieve this:

• an economic objective to help build strong, responsive and competitive economy
• a social objective to support strong vibrant and healthy communities
• an environment objective to protect and enhance our natural, built and historic environment

Changes to the planning system

This call for evidence is being undertaken in the context of a wider government focus on the planning system in England. The Levelling Up white paper, published in February 2022, set out a programme to reduce inequality and close the gap – in productivity, health, incomes and opportunity – between much of the southeast and the rest of the country. The paper also outlined how improvements to the planning system will be vital to secure these outcomes.

The Levelling Up and Regeneration Bill (the bill) was introduced to Parliament in May 2022 to provide the framework for delivering this agenda, including the legislative basis to improve the planning process.

The changes to the planning system in the bill seek to deliver high-quality design, enable the right infrastructure to come forward where it is needed, enhance local democracy and engagement, foster better environmental outcomes and allow neighbourhoods to shape their surroundings.

To support implementation of the bill, government is considering its vision for the future of national planning policy. This includes our proposals for the introduction of national development management policies, which will have a statutory role in guiding decision-making alongside the policies in development plans.

The future of national planning policy will be an opportunity to consider how plans and decisions can work to better deliver desired outcomes for the freight and logistics sector.

The evidence gathered through this call for evidence is primarily intended to provide support for future changes to the planning system. This could include:

• changes to national planning policy
• the development of national development management policies
• any associated changes required to the practice guidance

It may also be used to inform government thinking on the role of the nationally significant infrastructure projects regime.

Call for evidence

Scope

The FoF is clear that the planning needs of freight and logistics are wide-ranging and complex, reflecting the complexity and variation of the sector and that it is unlikely that any single intervention will address all its needs.

The FoF plan reported the concerns of the freight and logistics sector about the planning system and where the planning system has facilitated freight-related development, such as new warehouses and distribution hubs being built across the country in response to rapid growth in home delivery.

This call for evidence, therefore, has a scope based around these principles.

Multi-modal

Road, rail, aviation and maritime freight and warehousing and distribution.

Developments and operations

The impact of the planning system on all categories of freight-related development and on the operation of freight facilities.

National, regional and local

Planning system impact upon freight development and operations at a national, regional and local level.

Plan making and decision taking

Central government policy and local plan making and decisions on applications for development.

Impact on other government policy priorities

How freight, logistics and planning impacts net zero, growing and levelling up the economy, the resilience of UK supply chains and other strategic priorities.

What is working well today

To understand where the planning system is currently most effective for freight and logistics. This will reduce the risk of counter-productive interventions.

What is not working today

To understand where the planning system is currently least effective for freight and logistics. This will support prioritisation of any future interventions.

We, therefore, want to hear from those involved, directly or indirectly, in freight and logistics developments and operations. This includes:

• freight and logistics sector businesses
• developers and consultancies acting on behalf of freight and logistics businesses
• local authorities, including functions across planning, transport and highways with a focus on their experiences on working with the freight and logistics sector
• representative or trade bodies for the planning, transport, freight and logistics and other relevant sectors
• other organisations, such as subnational transport bodies, metro mayors’ offices and companies delivering zero emission energy infrastructure for freight
• interested and expert individuals, including but not limited to, academics, researchers, local residents near major logistics facilities, local community representatives, climate and environment experts and land policy experts

Objectives

The FoF sets out how the planning system is important to achieving the strategic objectives for freight and logistics identified in the plan – cost-efficient, resilient, reliable and environmentally sustainable.

The FoF plan sets out the strategic objective of a planning system that fully recognises the needs of the freight and logistics sector, now and in the future, and empowers the relevant planning authority to plan for those needs.

The primary objective of this call for evidence is to seek views so that the planning needs of the freight and logistics sector can be properly and effectively considered.

An enhanced evidence base will help to underpin any new or amended planning policies, reflecting the government’s vision and expectations for local planning authorities in planning for freight, to ensure sufficient land is allocated to service the needs of freight and logistics.

Specifically, the government has a suite of national planning policy and guidance tools that guide decision taking and plan making. Collectively, these enable the provision of development, including for the freight and logistics sector.

The evidence base generated by this call for evidence will therefore be used to inform actions which could include:

• changes to national planning policy
• development of national development management policies (NMMP)
• associated changes to the practice guidance
• updating guidance for local transport plans
• understanding the effectiveness of the nationally significant infrastructure projects regime and associated suite of national policy statements
• understanding capacity and capability challenges to develop interventions that address a disconnect between an industry that is not always equipped to effectively engage with the planning process and local planning authorities that do not always understand the land use needs of freight and logistics
• inform efforts to ensure planning authorities have a better understanding of how local policy and decisions can impact the wider regional, national and international freight system
• inform the needs, role and status of a national freight network
• identify opportunities to support the shared infrastructure priorities of England, Scotland, Wales and Northern Ireland and deliver greater connectivity across the Union

Evidence

Planning policies and decisions cannot consider the freight and logistics industry’s needs in isolation but must do so in the context of impacts on, for example, other transport network users, the environment and local communities.

To make the case for change and to meet the objectives set out above, we need to develop an improved qualitative and quantitative evidence base.

This could include:

• original empirical, analytic and case study research
• qualitative and statistical analysis of published documents
• results of consultative processes with networks and groups
• expert knowledge based upon past experiences, beliefs, values and skills – this is the most common evidence currently received and as such will be most value-adding if accompanied by additional evidence
• domestic and international best practice
• information relevant to the government’s strategic priorities – the opportunities and costs to the support, for example, for net zero, growing and levelling up the economy and improving the resilience of UK supply chains

More generally respondents should seek to provide examples of applications, local plan policies or other specific information that will help us to understand where efforts to deliver change may be best focused. Individual cases without wider context may not be as helpful to show the case for change.

Structure of questions

The questions in this call for evidence are structured in 3 sections:

• local plan making and land availability
• planning decision taking and the applications process
• how the planning system can support specific policy priorities

In each section, we ask questions to obtain evidence on the effectiveness of the current planning system for the freight and logistics sector. We are keen to understand both what is working well and why, what is not and why and what potential steps could be taken in response.

It is not necessary to answer all the questions. Focus on questions where you have strong evidence to support your response.

Questions

These questions are included here so you can read them in the context of this document.

See the Ways to respond section for this consultation for an online response form and other ways to respond.

Local plan making and land availability

Engagement with the freight and logistics sector, in particular, during engagement in the development of the FoF, highlighted concerns that local plans and the site selection and allocation process used to produce them, do not adequately support the sector to operate and grow to meet the government’s objectives for freight and logistics of efficiency, reliability, resilience and environmental sustainability.

Supporting freight operations is not only focused on finding new land, but also on security of use and the ability of operators to expand, consolidate, modernise facilities, particularly welfare and modify operations at existing sites.

Pivotal to success is ensuring that plan making by local transport authorities includes the freight and logistics sector as a key stakeholder.

Question 1

In your view, how effective are local plans at identifying development needs, and then allocating sites, for freight and logistics and how could this be improved?

In response to this question, you may want to think about:

• how this varies between different local planning authorities
• whether the location of allocated sites appropriately meets the needs of the sector, particularly in terms of good accessibility to the transport network
• any feedback you may have received following the submission of a site through a call for sites process
• what site constraints typically prevent development of land for freight and logistics infrastructure
• the extent to which local plans focus on warehouse and distribution infrastructure provision at the expense of other infrastructure and operational considerations required by the freight sector
• the level of data, information and evidence available to local planning authorities to determine the supply and demand needs for space
• any feedback you may have received when promoting sites for allocation in plans

Is there anything else that you consider relevant?

Question 2

How effectively are the policies in national planning policy (Chapter 6) and associated practice guidance applied by plan makers in supporting the needs of freight and how could this be improved?

In response to this question, you may wish to think about:

• whether existing planning policies and guidance are clear, consistent and have their intended impact
• how the needs case for freight and logistics is being considered at a local level, particularly where that case has regional or national significance
• the effect on the freight and logistics sector in relation to its efficiency, reliability, resilience and environmental sustainability

Is there anything else that you consider relevant?

Question 3

How effective is engagement between industry and local authorities in the course of local plan making? How can this be improved?

In response to this question, you may want to think about:

• the effectiveness of demonstrating the in-principle need for freight and logistics, particularly at the regional or strategic scale
• options that exist to enable developers and planning authorities to better understand these needs
• examples of where local plans have successfully planned for the needs of freight and logistics including what they did and why it worked
• whether local planning authorities have access to clear guidance and training for officers on planning requirements for freight and logistics

Is there anything else that you consider relevant?

Question 4

How effectively does planning currently support efficient use of established freight and logistics infrastructure? How could it better support existing infrastructure?

In response to this question, you may want to think about:

• making sites more space efficient, supporting innovation of site usage, policy or planning conditions required to densify operations and challenges to deliver this
• the effectiveness of permitted development rights supporting the industry
• how easy has it been to achieve consent for change of use or densification of sites to facilitate freight and logistics operations
• the use of design codes in driving intensification and in accommodating appropriate compatible uses
• the role scale of development, function and consolidation of functions can play
• whether there are any circumstances where development could be located nearer than currently allowed to more sensitive use classes including residential

Is there anything else that you consider relevant?

Question 5

How should freight and logistics be factored into statutory local transport plans and sub-national transport strategies?

In response to this question, you may want to think about:

• how our sub-national transport bodies, transport authorities and local planning authorities can better align transport and spatial planning across authority boundaries to identify improvements to the local transport networks that support the seamless movement of goods

Is there anything else that you consider relevant?

Planning decision taking and the applications process

Alongside concerns about the need for proper consideration of freight and logistics in the plan making process of local planning authorities, there were also concerns raised during the future of freight engagement about the decision taking and planning application processes of local planning authorities.

Supporting the freight and logistics sector to deliver efficient, reliable, resilient and sustainable supply chains, requires access to the right type of sites in the right places.

If the planning system is to support freight and logistics sites there must be clear and consistent application of planning policy and guidance in the granting of permission to use sites, with the process by which planning authorities take their decisions being well understood and navigable by the sector.

The questions in this section relate to decision taking and seek to gather evidence on experiences of application and best practice for planning decisions involving freight and logistics developments.

Question 6

What aspects of the applications and decision taking process work well and what aspects do not work well?

In response to this question, you may want to think about:

• where planning applications were the subject of pre-application advice
• capacity and capability of local decision taking, particularly in reference to understanding of freight and logistics
• reasons for refusal
• perceptions of the planning application stage in terms of proportion of applications that are approved and refused
• examples of aborted applications or development
• appraisal of the quality of planning applications for freight and logistics submitted

Is there anything else that you consider relevant?

Questions relating to specific policy priorities

Supporting supply chains

The FoF is clear that the government recognises the crucial role played by the freight and logistics sector in supporting every supply chain into, across and out of the country. The FoF plan sets out how the national freight and logistics network is a part of a larger global system and how the domestic network ranges from large international gateways and warehousing and distribution hubs to residential delivery.

Planning is not the only lever available to enhance the freight and logistics network in England, but it is an important one. This section focuses on how planning can support supply chains.

Here local plan making and decision taking remain important – for example, facilitating last-mile delivery – but there is also a strong interest in understanding how to align the planning system with the needs of the freight and logistics sector at a regional and national level.

The government also committed, in the FoF, to identify a national freight network. We will work to develop a fuller understanding of the domestic freight network across road, rail, maritime, aviation, inland waterway and warehouse infrastructure.

This will start with developing a stronger data and strategic picture of the network before exploring how this could be consolidated into a national freight network. With this process, we want to understand the role a national freight network could have in the planning system.

Question 7

How effective is the planning system at addressing the operational needs of the freight and logistics sector and how could this be improved? How could a national freight network be recognised in national planning policy?

In response to this question, you may want to think about:

• what are the priorities for improvement and what would need to change for those improvements to be realised?
• national, regional and local needs of the freight and logistics network and system
• how a national freight network could be recognised in national planning policy and the role the planning system could play to safeguard but also enhance key freight corridors and nodes in England
• the impact of the location of modal interchanges and distribution and storage hubs of different sizes within the freight and logistics network and system
• diversification, expansion, intensification of freight and logistics sites and operating restrictions – tension between efficiency and environmental impact
• the provision of land for freight and logistics in housing, office and retail developments including kerbside, delivery drop, and distribution hubs and the potential role for design guidance, nationally prescribed standards or standard conditions
• role of spatial and transport planning and local authorities in supporting adoption of innovative technology and operating models to grow and level up the economy
• mode specific regulation and guidance
• impact of freeports

Is there anything else that you consider relevant?

The decarbonisation of freight

The Transport decarbonisation plan sets the strategic direction with 78 commitments to put transport, including freight and logistics on an ambitious path to net zero by 2050.

The FoF prioritises the provision of net zero energy infrastructure and supporting modal shift by increasing the proportion of freight moved by rail, including the use of urban rail freight interchanges and other sustainable modes, such as cargo bikes, light rail and inland waterways.

The FoF also references urban and peri-urban freight consolidation centres, building on the commitment in Gear Change. Achieving net zero in freight will require infrastructure and maybe facilitated by land use or operational changes.

Question 8

How can the planning system support our net zero ambition for freight and logistics?

In response to this question, you may want to think about:

• how national planning policy and local plans and decisions can facilitate modal shift to low-carbon transport modes in urban, suburban and rural areas, including modal interchange, for example, rail freight interchanges
• how national planning policy and local plans and decisions can support the provision of zero emission energy infrastructure including charge points for, for example, large goods vehicle (LGVs) and heavy goods vehicles (HGVs) at freight facilities
• issues that impact specific modes including inland waterway and coastal shipping and air freight
• last-mile delivery including provision of consolidation centres, co-location of logistics and other land uses (for example, micro consolidation and distribution hubs operating from car parks) and mobile e-cargo bike stations
• how can distribution centres be located in more locations accessible by and connected to sustainable transport modes including public transport and the provision of cycle facilities

Is there anything else that you consider relevant?

HGV driver parking facilities and welfare

The government is committed to ensuring the planning system plays its part to meet the needs of hauliers and addressing current deficiencies, including the allocation of land for lorry parking.

We recently published DfT Circular 01 2022: strategic road network and the delivery of sustainable development, which explains how National Highways will engage with the planning system and addressing the requirements for roadside facilities, including HGV driver services. Nevertheless, there is more we can do.

Question 9

What more could local plans and decisions do to facilitate the supply of high-quality HGV parking and driver facilities?

In response to this question, you may want to think about:

• how the need for new and higher quality, more secure facilities (including adequate food, accommodation, toilet and shower facilities for men and women) can be conveyed to plan-makers and decision-takers and secured in the places they are needed
• how better HGV parking and driver welfare facilities can be delivered through the planning system at freight sites such as modal interchanges, distribution and logistics centres
• recognising the need for HGV parking facilities to be located close to the strategic road network or key road networks, what would help HGV parking facilities be better integrated into their surroundings and more acceptable to nearby local communities – how could these be encouraged through planning measures?
• how existing infrastructure (for example, vacant hardstanding land) can be better used through the planning system to accommodate HGV parking and what would unlock these sites

Is there anything else that you consider relevant?

Strengthening the Union

As a geographically distributed employer, the freight and logistics sector drives economic activity across the UK and contributes to both levelling up our economy and strengthening the Union. Government recognises that our national freight and logistics network is not constrained by internal borders – relying on all parts of the UK to be able to function effectively.

The following question seeks to identify opportunities in which the planning system in England can help to support the movement of freight across the UK and the delivery of shared infrastructure priorities of England, Scotland, Wales and Northern Ireland.

Question 10

How can planning policy in England help to support the freight and logistics sector across the whole of the UK?

In response to this question, you may want to think about:

• the interconnectivity of the freight and logistics network across the whole of the UK
• any examples of planning policy drawn from England and the devolved administrations that impact upon freight, whether positively or negatively
• is there anything else that you consider relevant?

How to respond

The call for evidence period began on 4 July 2023 and will run until 6 October 2023. Please ensure that your response reaches us before the closing date.

If you would like further copies of this call for evidence document, it can be found at DfT consultations or you can contact [email protected] if you need alternative formats, such as Braille, audio CD and large print.

Use our online response tool to submit your responses.

Alternatively, you can send your response to the call for evidence to:

Future of Freight
Logistics and Borders
Third Floor
Great Minster House
33 Horseferry Rd
London SW1P 4DR

Or email: [email protected]

When responding, state whether you are responding as an individual or representing the views of an organisation. If responding on behalf of a larger organisation, make it clear who the organisation represents and, where applicable, how the views of members were assembled.

There will be call for evidence events on 13 and 14 July 2023. If you would be interested in attending these events, email [email protected].

Questions list

Question 1

In your view, how effective are local plans at identifying development needs, and then allocating sites, for freight and logistics and how could this be improved?

Question 2

How effectively are the policies in the national planning policy (Chapter 6) and associated practice guidance applied by plan makers in supporting the needs of freight and how could this be improved?

Question 3

How effective is engagement between industry and local authorities in the course of local plan making? How can this be improved?

Question 4

How effectively does planning currently support more efficient use of established freight and logistics infrastructure and how could it better support existing infrastructure?

Question 5

How should freight and logistics be factored into statutory local transport plans and sub-national transport strategies?

Question 6

What aspects of the applications and decision taking process work well and what aspects do not work well?

Question 7

How effective is the planning system at addressing the operational needs of the freight and logistics sector and how could this be improved? How could a national freight network be recognised in national planning policy?

Question 8

How can the planning system support our net zero ambition for freight and logistics?

Question 9

What more could local plans and decisions do to facilitate the supply of high-quality HGV parking and driver facilities?

Question 10

How can planning policy in England help to support the freight and logistics sector across the whole of the UK?

Further information

Principles

The call for evidence is being conducted in line with the government’s key consultation principles.

If you have any comments about the call for evidence process, email [email protected] or write to:

Consultation co-ordinator

Department for Transport

Zone 1 / 29 Great Minster House

London SW1P 4DR

Freedom of Information

Information provided in response to this call for evidence, including personal information, may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000 (FOIA) or the Environmental Information Regulations 2004.

If you want information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory Code of Practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence.

In view of this, it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on DfT.

DfT will process your personal data in accordance with the Data Protection Act (DPA) and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties.

Confidentiality and data protection

The Department for Transport (DfT) and the Department for Levelling Up, Housing and Communities (DLUHC) are carrying out this call for evidence to gather evidence on the interaction between the freight and logistics sector and the planning system in England.

This consultation and the processing of personal data that it entails is necessary for the exercise of our functions as a government department. If your answers contain any information that allows you to be identified, DfT and DLUHC will, under data protection law, be joint controllers for this information.

As part of this call for evidence, we’re asking for your name and email address. This is in case we need to ask you follow-up questions about any of your responses. You do not have to give us this personal information. If you do provide it, we will use it only for the purpose of asking follow-up questions.

DfT’s privacy policy has more information about your rights in relation to your personal data, how to complain and how to contact the Data Protection Officer.

To receive this information by telephone or post, contact us on 0300 330 3000 or write to:

Data Protection Officer
Department for Transport
3rd Floor
One Priory Square
Hasting
East Sussex TN34 1EA

Your information will be kept securely on secure IT systems within DfT and DLUHC and will be destroyed within 24 months after the consultation has been completed.

DLUHC’s privacy policy also has more information about your rights in relation to your personal data, how to complain and how to contact the data protection officer.

If you have any concerns about how DLUHC is handling your personal information, you can email the DLUHC data protection officer at: [email protected].