Travel plan monitoring: baselines, targets and penalties

Travel plan monitoring is the part of the document that has legal teeth, and it is usually the part written last and worst. A travel plan without a baseline, dated surveys, numeric targets and a stated consequence for missing them is a statement of intent that nobody will ever test. Councils know that, which is why monitoring is increasingly secured through a section 106 obligation rather than a condition.

If you are drafting one, work backwards from the enforcement mechanism. Decide what happens if the targets are missed, then write the survey regime that would prove it.

What a travel plan has to commit to

Six commitments turn a narrative into a monitorable obligation.

• A named travel plan coordinator, with a role description and contact details supplied to the council
• A baseline survey, with a defined trigger and a defined method
• Numeric targets, expressed in the same units the survey produces
• A survey timetable naming the years and the months
• A menu of additional measures to be implemented if a target is missed
• A funding mechanism covering the coordinator, the surveys, the measures and the council's monitoring costs

Anything softer than that is unenforceable. A commitment to promote sustainable travel cannot be breached, so it cannot be relied on to make a development acceptable, and an officer who accepts it is storing up a problem for whoever inherits the file. The wider question of writing a travel plan a council will monitor covers the document as a whole, and what follows is the monitoring machinery inside it.

Setting the baseline survey and its timing

The baseline is the reference point every later survey is measured against, so the trigger has to be precise.

Two triggers are in common use: a stated period after first occupation, or a stated occupation percentage. The occupation trigger is better for phased schemes and worse for enforcement, because somebody has to establish when the threshold was reached. A hybrid works well: the earlier of nine months after first occupation or the date on which a stated proportion of units are occupied.

Survey in a neutral month. Avoid August, December, and the weeks either side of school holidays and half terms, because travel patterns shift and the resulting baseline flatters the scheme. Where the site is near a school or a university, note the term dates in the plan.

The method should be fixed in the document rather than left to the surveyor. State whether the survey is a self-completion questionnaire, an interview survey or an automated count, whether it covers residents, staff or visitors, the time periods captured, and how multi-modal trips are recorded. A baseline gathered by one method and a year three survey gathered by another produces a comparison nobody can defend.

Modal share targets and how they are expressed

Targets should be expressed as mode shares or as a reduction in single-occupancy car driver trips, with a date attached to each. Absolute trip numbers work for employment sites where the headcount is known and fail for residential schemes where occupancy changes.

Set interim targets as well as a final one, typically at years one, three and five. A single target at year five gives the developer no obligation for four years and gives the council nothing to act on.

Be realistic. A target requiring a 15 percentage point shift on a site with an hourly bus service will be missed, the remedial mechanism will be triggered, and everybody will spend money achieving nothing. Officers respect a modest target with a credible measures package more than an ambitious one with no delivery plan behind it.

Survey frequency and response rate thresholds

State the survey years, the month, and the minimum response rate that makes the result valid. Response rates are where monitoring quietly fails.

A self-completion residential survey achieving a low response rate tells you about the people who reply, not about the development. Set a minimum response rate in the plan, and set out what happens if it is not achieved: an extended survey period, a follow-up round, or an alternative method. Incentives are legitimate and should be described, because a survey with a prize draw and two reminder rounds performs very differently from one email.

Automated counts are worth pairing with questionnaires where a capacity constraint exists. A tube counter on the access for a fortnight gives a vehicle trip figure independent of who chose to answer a questionnaire, and it costs little compared with the argument it prevents. The trip rates used in the original Transport Assessment are the figures those counts will be compared against, so keep them accessible in the plan.

Remedial measures when a target is missed

The remedial mechanism is what makes the plan worth securing. It works best as a menu agreed at the outset with an escalation sequence.

1. The monitoring report identifies the shortfall and analyses the cause.
2. The coordinator proposes measures from the agreed menu, within a stated period.
3. The council approves or amends the proposal.
4. The measures are implemented within a stated period and funded from the travel plan budget.
5. The next survey tests whether the shortfall has closed, and the sequence repeats if it has not.

The menu should contain measures that can actually be delivered after occupation. Additional cycle parking, a car club space, a season ticket loan scheme, a subsidised bus pass contribution, improved wayfinding, a personalised travel planning exercise for new occupiers, or a change to parking management. Measures requiring construction on land the developer no longer controls do not belong on the menu, and nor do measures dependent on a third party's agreement unless that agreement is already in place. Where cycling is central to the strategy, the quantity, type and position of cycle parking determines whether adding more later is even possible.

Monitoring fees and financial mechanisms

Councils commonly seek a monitoring fee to cover the officer time spent reviewing reports and chasing compliance. Where that is secured through a section 106 agreement it has to satisfy the statutory tests for planning obligations, which means it must be necessary to make the development acceptable, directly related to the development, and reasonably related in scale and kind. Ask for the basis of the calculation, and resist a round number with no working behind it.

Financial penalties are a different mechanism and they are drafted in several ways. A sum payable if a target is missed. A bond released in tranches as targets are met. A contribution to a wider sustainable transport fund triggered by a shortfall. Each has a different effect on the developer's balance sheet and on the incentive to deliver, and the drafting should say whether payment discharges the obligation or whether the remedial measures still have to be implemented afterwards. That single point causes more disputes than the sums involved.

Who holds the coordinator role

The coordinator is a person, not a commitment. For an employment site it is usually a facilities or human resources manager with the role written into their objectives. For residential schemes it is normally the managing agent, which means the obligation has to survive a change of agent and the cost has to sit in the service charge.

Write the succession arrangement into the plan. Name the role rather than the individual, require the council to be notified within a stated period of any change, and make the obligation run with the land so that a sale does not extinguish it.

One honest uncertainty: enforcement of travel plan obligations is inconsistent, and many plans are never monitored at all once a site is built out. That is an argument for a simple, well-drafted regime with few surveys and clear triggers rather than an elaborate one nobody will administer. Draft the Travel Plan with the monitoring regime first and the narrative second.

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