MM89.

Object

Representation ID: 22715

Received: 03/05/2023

Respondent: Artisan PPS Ltd

Legally compliant? Not specified

Sound? Not specified

Artisan objects to the Transport Hierarchy in MM89. It conflates the attributes of travel with methods of travel. The consequence is that it has the potential to produce absurd results. For example, is a car which travels a shorter distance preferable to a high occupancy car that has to travel further? Moreover, what about low and ultra-low emissions vehicles? Trying to reduce the need and distance to travel is not an appropriate indicator given how rural the districts are. Indeed, the most recent AMR indicates that the 81% of housing in Mid Suffolk in the year 2021/22 was in 'rural areas'. What allowance does the hierarchy make for the difference in urban and rural areas in accordance with NPPFl0S?
The entire hierarchy is based on fossil fuel-based cars are harmful to the environment. However, the hierarchy needs to take into account all electric and other low/ultra-low emission vehicles.