Travel to Work Areas and Well-Connected Rail Stations: Proposed NPPF Updates

I was asked a question the other day about Footnote 26 to the December 2025 proposed draft of the NPPF, which is currently under consultation (thanks Owen).  I suspect that like me, you are wondering what Footnote 26 has to do with anything. I confess I needed to look it up.

In short, this relates to the proposed changes relating to development close to “well-connected rail stations”.  The footnote specifies where this policy will apply.  The same text is also featured in footnotes 45 and 52. Here is the text:

Well-connected rail stations and underground, tram and light rail stops are those in a top 60 Travel to Work Area located partially or fully within England by Gross Value Added (GVA) and which, in the normal weekday timetable, are served (or have a reasonable prospect of being served due to planned upgrades or through agreement with the rail operator) throughout the daytime by four trains or trams per hour overall, or two trains or trams per hour in any one direction.

I was asked which Travel to Work Areas would fall into scope. As someone who works in the field of economic development, it was presumed I would know something about this. Whilst I didn’t have the list at my fingertips, I was able to find something pretty quickly (see Figure 1).

During the 10 minutes of looking into this the cogs started turning in terms of whether this proposed definition was a good one.  Whilst there must be some sort of decision-making criteria, there are undoubtedly some oddities about the use of Travel to Work Areas (TTWA). Whether they are sufficient to mean an alternative is required, I am not sure, but there are certainly some anomalies.

For those of you unfamiliar with TTWAs, here is a very quick guide.

TTWAs are the official means for defining local labour market areas.  They are devised using Census commuting data.  They were first established after the 1970 Census.  The most recent iteration is based on data from the 2011 Census – with the impact of COVID-19 related public health restrictions impacting the validity of 2021 Census commuting data.

TTWAs are generally [1] areas where at least 75% of the resident workforce have jobs based in the area, and 75% of the jobs based in the area are filled by workers that live in the area. Basically, areas with a high level of self-containment. There are 228 TTWAs within the UK, of which 149 are in England – so the top 60 in terms of GVA accounts for around 40% of all the TTWAs in England.

Problems with using Travel to Work Areas to define well-connected rail stations under proposed NPPF updates

Three main issues strike me about the use of TTWAs in defining the policy for well-connected rail stations (there are no doubt others, but these will do for now!):

1. The TTWA definition does not allow places to be in more than one area. That means they have some major weaknesses in polycentric (sub)regions. In the real world commuters head in many different directions, and where there are multiple economic hubs in easy reach this causes a problem for TTWA design. For use in the NPPF proposals, it is a potential problem where a well-connected location falls outside one of the top 60 TTWAs, but has strong rail links to a major economic hub. Without doing any thorough forensic research I was able to identify a number of locations that could be deemed well-connected and met the other criteria, but would fall out of scope. For example:

• • Totnes in Devon. A small but popular town with a population of just under 10,000. It does not fall within one of the top 60 TTWAs but has rail connections that meet the remaining criteria to both Plymouth (under 30 mins, 3 trains per hour) and Exeter (30-40 mins, 3 tph). The station is also located in such a way that development outside the settlement boundary could be deemed within reasonable walking distance [2] of the station.
  • Wareham in Dorset (and other stations along the same line). Another small town in the South West of England. The train journey into Poole is 11 mins, and Bournemouth 25 mins with 2 tph in each direction.
  • Newsham, Northumberland. Located on the edge of Blyth, with other stations such as Blyth Bebside falling into the same category. It is 25 mins to Newcastle with minimum 2 tph and has development opportunities outside the settlement boundary within reasonable walking distance.

Why could these well-connected locations not make the same sort of contribution as those that just happen to be located in the top 60 TTWAs by GVA?  And why is 60 such a magic number – that feels pretty arbitrary?

2. TTWAs assume stable commuting patterns. This is an issue in this case because:

• • The data on which TTWAs were drawn up is now 15 years out of date, in those years there have been substantial shifts in working practices (anecdotal evidence suggests hybrid working is enabling workers to accept longer commutes given the journey needs to be made less frequently), as well as substantial levels of housing, employment and infrastructure development which could all have had substantial influence on commuting patterns; and
  • Building around stations has the potential to change commuting patterns, as do further planned infrastructure improvements.

If robust commuting data was available for 2026 (or 2021 for that matter) I suspect there would be some notable differences in the TTWAs that emerged, even using the same algorithm as has been used previously. The number of TTWAs reduced between the 2001 and 2011 Census and as this continued a consistent trend I suspect the same would happen again if newer data was used.

3. TTWAs do not relate well to administrative boundaries. This is probably the least problematic, but with planning decision making largely structured around local authority boundaries (I appreciate this will be changing with the advent of spatial development strategies), the use of TTWAs for geographic decision making adds another layer of complexity.

I haven’t even got into the question of the fact that as each new set of GVA data is released the top 60 TTWAs could change.  What happens to schemes in areas that drop out of the top 60, can they still proceed?  Some greater clarity on this will be required.

As a final aside, if retained, I hope the wording of the final draft NPPF is tightened up as a minimum. If you take a straight assessment of the top 60 based on the most recent GVA data there are seven areas that lie outside England. Does the text as currently drafted mean there are actually only 53 eligible areas, or should the next seven English areas be added to the list (as shown in Figure 1)?  I can imagine a situation developing with barristers arguing the toss over this in due course unless there is greater clarity.

Is there an alternative?  It is always easier to diagnose the problem than craft the solution.  But if the objective is to identify “well connected” rail stations in reach of key economic hubs this could easily be done by setting out a schedule of hubs in an appendix to the NPPF, and retaining criteria for determining well-connectedness such as the number of trains per hour and the length of journey time.  The appendix could be updated from time to time if necessary, but would provide a greater level of certainty.

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[1] There is some flexibility on thresholds, so for some very densely populated areas lower self-containment rates are accepted.

[2] This isn’t defined in NPPF but for the purposes of this note I have assumed 800m in line with walkable neighbourhoods recommendations. Town and Country Planning Association. (March 2021). 20-Minute Neighbourhoods: Creating Healthier, Active, Prosperous Communities — An Introduction for Council Planners in England. Town and Country Planning Association. Available at https://www.tcpa.org.uk/wp-content/uploads/2021/11/final_20mnguide-compressed.pdf  (accessed 14/1/2026)

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Hardisty Jones help local authorities, pan-regional partnerships, and others to understand their local economies and the opportunities and challenges they are likely to face, to help guide future development activity and attract funding and investment to deliver this activity. Read more about how we can help deliver an economic development strategy.